Comment on CFTC-2026-0331, CFTC-2026-0331-0001, First, Research

Summary: First Strike Research supports the proposed rulemaking but argues that the current ANPRM is insufficient to address specific market integrity failures. They propose five specific remedies: establishing a dedicated prediction market-specific Self-Regulatory Organization (PM-SRO), prohibiting dual branding between registered and unregistered platforms, requiring algorithmic trading disclosures, enforcing uniform API and public data standards, and addressing specific recent market manipulation cases.