Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Chen, Arad

Summary: Solidus Labs, a trade surveillance and market integrity firm, supports the proposed rulemaking but argues that prediction markets require specialized surveillance frameworks distinct from traditional futures markets. They advocate for specific regulatory expectations regarding cluster-based identity analysis, cross-symbol detection, and integrated cross-on-and-off-chain monitoring to address unique manipulation typologies.