I would say that if this was a institutional approach (à la Airton Risk) where companies with real skin in the game (sponsors, companies that have economic implications etc) where they can hedge then yes, I think then this would not be labeled as gambling.
But everyone in the industry is going in this route (CFTC) because it’s an easier way to offer their products and make it as a company.
Alex, your product is great, my assumptions is the reason you want to get a DCM approval and go national is to scale this great product to millions of people and not to offer some kind of way to get ahead
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