Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Aidan, Lilani

Re: Advance Notice of Proposed Rulemaking on Prediction Markets, RIN 3038-AF65 I am a member of the Cassandra Association and a supporter of Cassandra Laboratories Foundation, Inc. My background is in fintech, and I currently work in partnerships at an AI company. I ve spent my career watching regulatory frameworks get built for the dominant players in a category and then watching smaller, mission-driven organizations struggle to operate under rules that were never designed with them in mind. That pattern is playing out again here. When I look at prediction markets, I don t see one category. I see two: commercial platforms built around volume, engagement, and monetization, and nonprofit research platforms built around something different generating reliable probability signals on events that matter to the public. The first category can absorb significant compliance overhead. The second often can t. A framework calibrated to the first will quietly eliminate the second, not through intent but through structural friction. What draws me to nonprofit prediction markets is the public information function they serve. Probability estimates on scientific, policy, and civic events give people, journalists, researchers, and institutions a way to reason about uncertainty that polling or punditry doesn t provide. That function doesn t survive if the only entities that can afford to operate prediction markets are commercial platforms with different incentives. The Commission s fair competition analysis should account for this asymmetry. Fair rules applied to structurally unequal participants produce unequal outcomes. The Commission has already implicitly recognized that nonprofit research markets are a distinct category its own prior no-action letters reflect that. The question is whether that recognition gets codified into durable regulatory architecture, or stays buried in discretionary staff letters that the next applicant has to relitigate from scratch.