Comment Text:
I am submitting this comment as an individual to address Questions 10 and 1 of the Advance Notice of Proposed Rulemaking. My perspective is shaped by my role as a Vice President at Mad River Glen Capital, a tech buyout fund, where I focus on growth-stage private market investments and strategic finance for startups.
In private equity, we often evaluate companies in "frontier" sectors—such as the US electricity grid, supply chain logistics, and the application layer of Large Language Models. Valuation in these spaces is frequently tied to exogenous events like regulatory shifts or specific technological milestones that lack traditional hedging instruments or liquid market signals. Nonprofit prediction markets serve as a vital data layer for pricing these risks. They disseminate high-signal pricing information that directly informs how we allocate capital in the broader economy. The Commission should recognize that the "price discovery" occurring in research-focused markets provides unique utility that commercial exchanges do not.
Furthermore, my experience in strategic finance has shown me how excessive operational overhead can quickly destroy the utility of a project. Applying the full weight of DCM Core Principles to small-scale research platforms creates a compliance tax that makes nonprofit price discovery economically impossible. The Commission should codify a specific, streamlined regulatory pathway for nonprofit entities rather than continuing to rely on discretionary, case-by-case letters. We should acknowledge that a research-driven data source is a fundamentally different market type than a high-volume commercial platform.
