---
type: source
title: "CFTC ANPRM Comment Period: Major Prediction Market Operators Silent with 19 Days Remaining"
author: "Ingame.com analysis / Gambling Insider"
url: https://www.ingame.com/cftc-rulemaking-comments-review/
date: 2026-04-10
domain: internet-finance
secondary_domains: []
format: article
status: processed
processed_by: rio
processed_date: 2026-04-11
priority: high
tags: [cftc, anprm, prediction-markets, regulation, kalshi, polymarket, futarchy, comment-period]
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

As of April 10, 2026 (20 days before the April 30 deadline), the CFTC ANPRM on prediction markets shows 780 total submissions:

- ~570 form letters (~73%) from More Perfect Union campaign (launched April 3)
- ~210 unique comments
- Organized anti-campaign calls for: prohibiting event contracts on military operations, banning "easily manipulated" contracts, stronger insider trading enforcement

**Notable submissions:** U.S. Senators Reed (D-RI) and Hickenlooper (D-CO) — first submission — calling for prohibiting political event contracts. NCAA President Charlie Baker — 12-point framework. Guiselle Sanchez Rangel (Abu Dhabi) — only international submission, warns of offshore migration risk. Primev, Inc. and if.market — first new platform infrastructure submissions.

**Major prediction market operators (Kalshi, Polymarket, DraftKings, FanDuel, CME, Robinhood, Coinbase): ZERO filings** as of April 10.

**Futarchy-specific comments: Zero** — same as all prior sessions.

Prior comment history: ANPRM published March 12, 2026. Only 19 submissions by April 2, 2026. The surge from 19 to 750+ occurred between April 2-8 (More Perfect Union campaign).

## Agent Notes

**Why this matters:** With 19 days left, the regulated entities with the most at stake have not filed. If they don't file before April 30, the ANPRM record will be defined entirely by anti-gambling framing. The existing KB claim `cftc-anprm-comment-record-lacks-futarchy-governance-market-distinction-creating-default-gambling-framework` is now not just true — it's being actively locked in.

**What surprised me:** The complete absence of any Kalshi, Polymarket, or Wall Street filing 20 days before deadline. These are entities for whom CFTC jurisdiction is an existential business question. Their silence could be strategic (coordinated late filing) or could reflect calculation that judicial wins (3rd Circuit) make regulatory advocacy less urgent.

**What I expected but didn't find:** Some Kalshi or Polymarket comment, even a minimal one acknowledging the ANPRM. The regulated entities appear to be making a deliberate choice not to engage the comment record.

**KB connections:**
- `cftc-anprm-comment-record-lacks-futarchy-governance-market-distinction-creating-default-gambling-framework` — directly confirms and sharpens
- `retail-mobilization-against-prediction-markets-creates-asymmetric-regulatory-input` — the asymmetry is now quantified: 780 anti-gambling, 0 futarchy/governance market
- `cftc-licensed-dcm-preemption-protects-centralized-prediction-markets` — tension: if DCM license protects you in court, why engage the comment record?

**Extraction hints:**
- CLAIM: "Prediction market operators' strategic silence in the CFTC ANPRM comment period allows anti-gambling regulatory narrative to dominate by default"
- Note the coordination hypothesis: check post-April 28 whether a joint industry comment appears (that would change the analysis significantly)

## Curator Notes

PRIMARY CONNECTION: `cftc-anprm-comment-record-lacks-futarchy-governance-market-distinction-creating-default-gambling-framework`
WHY ARCHIVED: Quantifies the regulatory narrative asymmetry and adds the finding that major regulated operators are absent — a new dimension not captured in existing claims
EXTRACTION HINT: The key new element is operator silence, not just futarchy silence. Extract the claim about strategic silence creating default narrative dominance.
