Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Emma, Brunelle

Summary: The Fond du Lac Band of Lake Superior Chippewa, a federally recognized Indian tribe, opposes the expansion of prediction markets, arguing that they function as unlawful gambling rather than permissible derivatives. They contend that these markets undermine the Indian Gaming Regulatory Act (IGRA), threaten tribal economic interests, and lack legitimate price discovery or hedging functions.