Comment Text:
Dear Chairman and Commissioners,
My name is Kahlia Mafua, and I'm a marketing professional from Washington state writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm new to prediction markets, but I strongly support their development under fair, proportionate regulation by the CFTC.
As someone working in marketing, I see real economic value in these markets, especially for hedging personal career risks. For example, I've been looking into event contracts tied to whether AI will take over substantial marketing jobs in the coming years. This isn't gambling to me; it's a practical way to protect myself against a very real financial threat. If AI disrupts my industry, having a stake in a prediction market could offset some of the impact on my income. This kind of hedging is no different from how people use other financial tools to manage uncertainty, and I don't believe it should be labeled as "gaming."
I'm aware there are concerns about manipulation or insider trading, but I believe the CFTC already has strong tools to handle those issues. You've got authority to crack down on bad actors in any regulated market, and that should apply here too. Banning or over-restricting prediction markets doesn't solve the problem; it just pushes activity to unregulated offshore platforms where there's no oversight at all. That’s worse for consumer protection, not better. Instead, let's keep these markets here in the US, under your watch, and position our country as a leader in financial innovation. We shouldn't be handing that edge to other nations.
I'd like to address a couple of specific questions from the ANPR. On Question 15, about defining gaming versus legitimate markets, I urge you to recognize event contracts as economic tools for hedging and price discovery, not gambling. On Question 7, regarding balancing innovation and consumer protection, I believe targeted rules addressing specific risks are far better than broad categorical bans. Focus on enforcing existing laws against manipulation and insider trading rather than shutting down entire markets.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Keep them legal, regulated, and accessible to people like me who see real value in participating. Thank you for considering my perspective.
Sincerely,
Kahlia Mafua
