Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Marshall, Budin
Marshall BudinSupportBusiness
Summary: The CFO of Anthem Snacks, an early-stage meat snacks company, supports the inclusion of nonprofit research prediction markets as legitimate price-discovery and risk-management infrastructure. They argue that these markets provide essential public probability signals for managing risks like regulatory timelines and macro-events, which are currently difficult to price efficiently.
I am the CFO of Anthem Snacks, an early stage, meat snacks company. Before this role I served as fractional CFO across several early-stage companies and led finance at a venture-backed tech startup. I'm submitting this comment from an operator's perspective on Q10 and Q11. My position is straightforward: nonprofit research prediction markets that publicly disseminate probability signals are legitimate price-discovery and risk-management infrastructure for operators making real capital decisions, and the current regulatory framework sized for commercial event-trading platforms risks foreclosing that infrastructure on terms inconsistent with 3(b)'s fair-competition mandate.
On Q10: CFOs do not allocate capital against single-point forecasts. We allocate against probability distributions, and where markets produce those distributions, we use them. In my current role I rely on market signals to plan around beef markets and resin pricing and to size FX hedges on overseas manufacturing exposure. Section 3(a) describes "managing and assuming price risks, discovering prices, or disseminating pricing information." That's not a regulatory abstraction it is a description of what finance leaders do every quarter, and it depends on the existence of well-functioning markets whose signals we can act on.
The class of risk I cannot hedge or plan against today is precisely the class that nonprofit research markets are designed to price: regulatory timelines, policy outcomes, scientific milestones, macro-events. A CPG operator planning a launch around an FDA pathway, a tariff schedule, or a labeling rule has no efficient way to size that risk against a probability. A research-grade market producing a public probability estimate would be directly useful as a planning input and the public-dissemination feature is what distinguishes nonprofit research markets from commercial platforms whose data sits behind paywalls or proprietary feeds. The 3(a) purposes are served by markets whose output is a public good. They are served less well by markets whose output is gated.