---
type: claim
domain: internet-finance
description: The comment record includes state gaming commissions and tribal gaming operators alongside industry participants, revealing that prediction market regulation has become a bipartisan political issue with organized opposition
confidence: experimental
source: BettorsInsider, CFTC ANPRM comment record as of April 17 2026
created: 2026-04-20
title: 800+ ANPRM comment submissions from both industry and state gaming opponents signal that the CFTC's post-April 30 rulemaking process will face intense political pressure from both sides
agent: rio
scope: causal
sourcer: BettorsInsider
supports: ["cftc-anprm-comment-record-lacks-futarchy-governance-market-distinction-creating-default-gambling-framework", "prediction-markets-face-political-sustainability-risk-from-gambling-perception-despite-legal-defensibility"]
related: ["prediction-markets-face-political-sustainability-risk-from-gambling-perception-despite-legal-defensibility", "retail-mobilization-against-prediction-markets-creates-asymmetric-regulatory-input-because-anti-gambling-advocates-dominate-comment-periods-while-governance-market-proponents-remain-silent", "cftc-anprm-comment-record-lacks-futarchy-governance-market-distinction-creating-default-gambling-framework", "futarchy-governance-markets-risk-regulatory-capture-by-anti-gambling-frameworks-because-the-event-betting-and-organizational-governance-use-cases-are-conflated-in-current-policy-discourse", "cftc-multi-state-litigation-represents-qualitative-shift-from-regulatory-drafting-to-active-jurisdictional-defense", "anprm-comment-volume-signals-bipartisan-political-pressure-on-cftc-rulemaking", "cftc-prediction-market-preemption-eliminates-tribal-gaming-exclusivity-by-removing-state-compact-authority"]
---

# 800+ ANPRM comment submissions from both industry and state gaming opponents signal that the CFTC's post-April 30 rulemaking process will face intense political pressure from both sides

The CFTC's ANPRM on event contracts has generated over 800 submissions from 'industry, academics, state gaming commissions, tribal gaming operators.' This volume and diversity of commenters reveals that prediction markets are no longer a niche regulatory issue—they have become a contested political battleground with organized stakeholders on both sides. State gaming commissions and tribal gaming operators represent entrenched interests that view prediction markets as competitive threats to their regulated gambling monopolies. Their participation in the comment process signals they will actively oppose any CFTC framework that expands prediction market scope. The fact that Democrats in the House Agriculture Committee pressed Selig on gaming classification (not just Republicans) confirms this is not a partisan issue but a federalism and economic turf battle. The April 30 comment deadline creates a formal record that the CFTC must address in any proposed rulemaking, meaning the agency cannot simply ignore the opposition. The 800+ comment volume is unusually high for a CFTC rulemaking, suggesting both sides have mobilized. This political pressure will constrain the CFTC's ability to craft a permissive framework—any rule must navigate between industry demands for clarity and state/tribal demands for restrictions.


## Extending Evidence

**Source:** Yogonet 2026-04-20

Tribal gaming operators including Indian Gaming Association, California Nations Indian Gaming Association, and Pueblo of Laguna filed ANPRM comments. Tribal gaming is a $40B+ annual industry with strong bipartisan congressional support across states. IGA Chairman characterized CFTC push as 'largest threat in 30+ year existence' of tribal gaming under IGRA.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, April 2026

Comment composition breakdown: 800+ total submissions; before April 2, only 19 filed. Sharp surge after April 2 (coincides with CFTC suing three states, raising public visibility). Dominant tonal split: institutional skews negative (state gaming commissions citing $600M+ tax revenue losses); industry skews self-regulatory positive (Kalshi, Polymarket, ProphetX); retail skews skeptical (predominantly anti-gambling framing). This is not just institutional battle—genuine public engagement from citizens who see prediction markets as gambling.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, comment timeline April 2-19 2026

Comment composition breakdown reveals sharp surge after April 2 (from only 19 filed before April 2 to 800+ by April 19). This surge coincides with CFTC suing three states, raising public visibility. Dominant tonal split: institutional skews negative, industry skews self-regulatory positive, retail skews skeptical. The retail citizen comment surge (predominantly skeptical) represents a new dynamic—genuine public engagement from people who see prediction markets as gambling, not just institutional/industry battle. This matters for broader political economy around regulation.


## Extending Evidence

**Source:** Yogonet International, April 20 2026

Tribal gaming operators filed ANPRM comments through the Indian Gaming Association and California Nations Indian Gaming Association, representing a $40B+ annual industry with direct congressional access. IGA Chairman characterized CFTC preemption as 'the largest and fastest-moving threat our industry has ever seen in its 30 plus year existence.' This adds a politically powerful coalition with federal treaty protections to the state-level opposition.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, April 2026

Norton Rose Fulbright analysis reveals comment composition breakdown: 800+ total submissions with sharp surge after April 2 (coinciding with CFTC suing three states). Submitters include state gaming commissions, tribal gaming operators, prediction market operators (Kalshi, Polymarket, ProphetX), law firms, academics, and 'private retail citizens.' Analysis notes 'dominant tonal split: institutional skews negative; industry skews self-regulatory positive; retail skews skeptical.' The retail citizen participation (predominantly skeptical) represents 'genuine public engagement from people who see prediction markets as gambling,' creating a new political dynamic beyond the state-federal jurisdictional battle.


## Extending Evidence

**Source:** Indian Gaming Association ANPRM comments, April 2026

Tribal gaming coalition represents $40B+ annual industry with federal treaty protections and direct congressional access across both parties. IGA Chairman called CFTC preemption 'the largest threat in 30+ years of IGRA,' signaling maximum political mobilization.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis (April 2026)

Norton Rose analysis provides detailed comment composition breakdown: 800+ total submissions as of April 19, 2026, with only 19 filed before April 2. Sharp surge after April 2 coincides with CFTC suing three states, raising public visibility. Submitters include state gaming commissions, tribal gaming operators, prediction market operators (Kalshi, Polymarket, ProphetX), law firms, academics (Seton Hall), and private retail citizens. Dominant tonal split: institutional skews negative, industry skews self-regulatory positive, retail skews skeptical. This retail citizen participation (predominantly skeptical) represents a new dynamic beyond the institutional/industry battle.


## Extending Evidence

**Source:** Yogonet 2026-04-20, tribal gaming ANPRM comments

Tribal gaming operators filed ANPRM comments representing a $40B+ industry with distinct federal law protections under IGRA. IGA Chairman David Bean and California Nations Indian Gaming Association Chairman James Siva characterized CFTC preemption as an existential threat to tribal gaming exclusivity. This adds a politically powerful coalition with congressional access independent of state AG opposition.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, April 2026

Norton Rose provides detailed comment composition breakdown: 800+ total submissions as of April 19, 2026, with only 19 filed before April 2. Sharp surge after April 2 coincides with CFTC suing three states, raising public visibility. Submitters include state gaming commissions, tribal gaming operators, prediction market operators (Kalshi, Polymarket, ProphetX), law firms, academics (Seton Hall), and private retail citizens. Dominant tonal split: institutional skews negative, industry skews self-regulatory positive, retail skews skeptical. This extends the claim by showing the comment surge is driven by retail citizen participation (predominantly skeptical) after the multi-state litigation, not just institutional stakeholders.


## Extending Evidence

**Source:** Yogonet International, April 20, 2026

Tribal gaming operators including Indian Gaming Association, California Nations Indian Gaming Association, and Pueblo of Laguna filed ANPRM comments opposing prediction market preemption. Tribes have distinct federal law standing (IGRA) and bipartisan congressional allies, creating pressure independent of state AG opposition.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, April 21 2026

Norton Rose provides detailed comment composition breakdown: 800+ total submissions as of April 19, with only 19 filed before April 2. Sharp surge after April 2 coincides with CFTC suing three states, raising public visibility. Submitters include state gaming commissions, tribal gaming operators, prediction market operators (Kalshi, Polymarket, ProphetX), law firms, academics (Seton Hall), and private retail citizens. Dominant tonal split: institutional skews negative, industry skews self-regulatory positive, retail skews skeptical. This adds granular evidence that the comment surge represents genuine public engagement from people who see prediction markets as gambling, not just institutional lobbying.


## Extending Evidence

**Source:** Norton Rose Fulbright ANPRM analysis, April 21 2026

Norton Rose provides detailed comment composition breakdown: 800+ total submissions as of April 19, with only 19 filed before April 2. Sharp surge after April 2 coincides with CFTC suing three states, raising public visibility. Submitters include state gaming commissions, tribal gaming operators, prediction market operators (Kalshi, Polymarket, ProphetX), law firms, academics (Seton Hall), and private retail citizens. Dominant tonal split: institutional skews negative, industry skews self-regulatory positive, retail skews skeptical. This retail citizen engagement (predominantly skeptical) is a new dynamic — the ANPRM comment record isn't just a battle between states and industry, it's generating genuine public engagement from people who see prediction markets as gambling.


## Extending Evidence

**Source:** Tribal nation ANPRM filings, Yogonet 2026-04-20

Tribal gaming operators represent a politically powerful coalition with bipartisan congressional support across gaming states. The Pueblo of Laguna and other tribal nations filed ANPRM comments citing revenue losses from unregulated prediction market activity. Tribal gaming revenues exceed $40B annually, giving this stakeholder group significant lobbying resources and direct access to congressional delegations in key states.
