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Comment for Proposed Rule 91 FR 12516

  • From: Michael Franz
    Organization(s):
    N/A

    Comment No: 115322
    Date: 4/29/2026

    Comment Text:

    Dear Chairman and Commissioners,

    I am writing to you today as a professional investor and a former high school government and economics teacher to express my strong support for the continued growth of prediction markets. I respectfully urge the Commission to foster the development of these platforms rather than stifling them under overly burdensome regulatory frameworks.

    In the chaotic early days of the COVID-19 pandemic, I, like many Americans, was desperate for accurate information. Sifting through conflicting media reports, evolving health directives, and competing models to gauge the true threat of the virus felt nearly impossible. I found myself profoundly wishing that prediction markets had the regulatory leeway to offer robust contracts on COVID-19. A liquid market forecasting the deadliness of the disease, its rate of spread, and a realistic timeline for vaccine development would have been invaluable. In a period of such extreme uncertainty, these markets could have provided an objective baseline to help inform critical life-or-death decisions for myself and my family.

    The fundamental beauty of economics is that markets solve the problem of dispersed knowledge, distilling fragmented information from thousands of individuals into a single, clear metric: price. Prediction markets take this mechanism and require participants to back their forecasts with their own capital. This "skin in the game" efficiently filters out noise and bias, as financial incentives relentlessly reward accuracy. Because of this dynamic, I believe prediction markets are the most accurate predictive tool in the history of mankind.

    The data generated by these platforms extends far beyond the traders participating in them. By providing transparent, real-time, financially backed probabilities on everything from economic indicators to public health outcomes, prediction markets serve as an invaluable public utility.

    I fully respect the CFTC’s mandate to protect market integrity and prevent malicious manipulation. However, I strongly caution against taking a heavy-handed approach to this emerging sector. Attempting to eliminate every theoretical risk by severely restricting the contracts these platforms can offer would be a grave mistake; to overregulate this space would be to throw the baby out with the bathwater. Sweeping prohibitions will simply drive this financial innovation offshore, depriving the American public of vital, localized data.

    I respectfully ask that the CFTC adopt a balanced, light-touch regulatory approach that protects basic market integrity while allowing this essential forecasting tool to reach its full potential.

    Sincerely,
    Michael Franz

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