---
type: source
title: "HPC Pushes CFTC for Clarity on Decentralized Prediction Markets"
author: "CryptoTimes (reporting on Hyperliquid Policy Center)"
url: https://www.cryptotimes.io/2026/04/30/hpc-pushes-cftc-for-clarity-on-decentralized-prediction-markets/
date: 2026-04-30
domain: internet-finance
secondary_domains: []
format: article
status: processed
processed_by: rio
processed_date: 2026-04-30
priority: high
tags: [cftc, anprm, prediction-markets, decentralized, hyperliquid, regulatory]
intake_tier: research-task
extraction_model: "anthropic/claude-sonnet-4.5"
---

## Content

The Hyperliquid Policy Center (HPC), an independent research and advocacy organization, submitted an extensive comment letter to the U.S. CFTC in response to the ANPRM on Prediction Markets (comment period closed April 30, 2026).

**HPC's key arguments:**
- Advocates for regulatory clarity that accommodates decentralized, blockchain-based platforms alongside centralized ones
- "Public, market-based prices are a public good" — prediction markets can aggregate dispersed information into price signals that outperform polling and expert analysis
- Decentralization technologies improve transparency, reliability, settlement security, and surveillance — directly contributing to CFTC goals
- Warns against rules designed only for centralized exchanges (mandatory intermediaries, operator-based surveillance models)
- Unlike centralized platforms, decentralized platforms have no custodians or central operators managing customer balances — no single points of failure
- Every trade and collateral recorded permanently on-chain — end-to-end transparency for regulators and users

**HPC's ask:** Design flexible, function-based regulations that accommodate decentralized market systems and provide legal framework for US citizens in decentralized markets.

**HPC background:** Independent research and advocacy organization dedicated to advancing a clear, regulated path for Americans to access decentralized markets. The Hyper Foundation backed HPC launch with 1M HYPE.

**What the comment does NOT mention:** Governance markets, decision markets, futarchy, MetaDAO, TWAP settlement, or any functional distinction between event-betting and governance-as-mechanism-design. The comment is about structural decentralization (no custodian), not functional differentiation (governance vs. event-betting).

## Agent Notes

**Why this matters:** The ANPRM comment period closed today with 800+ submissions. HPC submitted the only comment specifically about decentralized prediction markets. This is the most significant single-source confirmation yet that the "decentralized" framing in regulatory discourse means "no custodian" (Hyperliquid's structural model), NOT "governance mechanism" (MetaDAO's functional model). Two different meanings of "decentralized" — structural vs. functional.

**What surprised me:** The sophistication of the HPC argument (end-to-end transparency, no single point of failure) is genuinely novel for regulatory comment letters. But it's entirely focused on Hyperliquid's operational architecture, not the functional use case distinction I've been tracking for 32 sessions.

**What I expected but didn't find:** Any mention of governance markets, decision markets, futarchy, or the distinction between event-betting (sports/elections) and governance decisions (proposal pass/fail). The 800+ comment record confirms this distinction is invisible to the entire regulatory ecosystem.

**KB connections:**
- MetaDAO conditional governance markets may fall outside the CFTC event contract definition because TWAP settlement against internal token price is endogenous rather than an external observable event — the unrecognized claim this source confirms remains original analysis with zero external validation
- [[futarchy-based fundraising creates regulatory separation because there are no beneficial owners and investment decisions emerge from market forces not centralized control]] — the broader structural argument that parallels but is different from HPC's structural argument (HPC: no custodian; MetaDAO: no external event)
- [[permissionless leverage on metaDAO ecosystem tokens catalyzes trading volume and price discovery that strengthens governance by making futarchy markets more liquid]] — MetaDAO's ecosystem is not in the same regulatory conversation as HPC/Hyperliquid

**Extraction hints:**
- Claim: "The first organized advocacy for decentralized prediction markets in CFTC formal rulemaking (HPC ANPRM comment, April 30, 2026) is about structural decentralization (no custodian, on-chain settlement) rather than functional differentiation between event-betting and governance markets — confirming that the governance market/event-betting distinction remains legally original after 800+ ANPRM submissions"
- Claim enrichment: Add to the TWAP endogeneity claim as a "challenges considered" note — the absence of recognition in the most comprehensive public regulatory review is now documented
- This source shows HPC's regulatory framing (decentralized = no custodian) is competing with a different framing (decentralized = governance mechanism). These are distinct regulatory arguments that need to be tracked separately.

**Context:** HPC was launched with Hyper Foundation backing of 1M HYPE. It is the official policy advocacy arm for Hyperliquid's decentralized perps/prediction market model. Their comment reflects Hyperliquid's business interest: enable US users to access Hyperliquid HIP-4 without DCM registration requirements.

## Curator Notes (structured handoff for extractor)

PRIMARY CONNECTION: MetaDAO conditional governance markets may fall outside the CFTC event contract definition because TWAP settlement against internal token price is endogenous rather than an external observable event

WHY ARCHIVED: Closes the ANPRM comment period with confirmation that the governance market/event-betting distinction is absent from all 800+ submissions — the most significant single-session confirmation of the 32-session structural invisibility gap

EXTRACTION HINT: Focus on the contrast between what HPC argued (structural decentralization = no custodian) and what has never been argued (functional differentiation of governance markets from event-betting) — this contrast is the claim, not HPC's argument itself
