The first organized advocacy for decentralized prediction markets in CFTC formal rulemaking (HPC ANPRM comment, April 30, 2026) is about structural decentralization (no custodian, on-chain settlement) rather than functional differentiation between event-betting and governance markets — confirming that the governance market/event-betting distinction remains legally unrecognized after 800+ ANPRM submissions

The Hyperliquid Policy Center submitted the only comment in the 800+ ANPRM submissions specifically addressing decentralized prediction markets. The comment's entire argument centers on structural properties: no custodians or central operators managing customer balances, every trade and collateral recorded permanently on-chain, end-to-end transparency for regulators. HPC warns against rules designed only for centralized exchanges (mandatory intermediaries, operator-based surveillance models) and advocates for flexible, function-based regulations that accommodate decentralized market systems. Critically, the comment makes zero mention of governance markets, decision markets, futarchy, MetaDAO, TWAP settlement, or any functional distinction between event-betting (sports/elections) and governance-as-mechanism-design. This is significant because HPC had the opportunity to introduce the governance market distinction into the formal regulatory record during the most comprehensive public review of prediction market regulation to date. The absence confirms that 'decentralized' in regulatory discourse means 'no custodian' (Hyperliquid's structural model), not 'governance mechanism' (MetaDAO's functional model). The 800+ comment record now provides documented evidence that the governance market/event-betting distinction is invisible to the entire regulatory ecosystem, including sophisticated advocacy organizations with direct financial interest in regulatory clarity.