Comment Text:
Dear Chairman and Commissioners,
My name is Marc Pedersen, and I'm a business owner from New York. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I'm fairly new to prediction markets, but I strongly support their existence under fair and clear regulation. As someone who runs a business, I value the freedom to participate in legal, regulated financial tools, and I believe these markets have a lot to offer if handled right.
I see prediction markets as a unique way to gain insights that aren't available through traditional sources. They're not just for traders; the information they provide can help businesses like mine make better decisions, especially when it comes to hedging against economic or political uncertainties. But beyond my personal interest, I think these markets are vital for keeping the US competitive in financial innovation. We should be leading the charge here, not letting other countries take the reins because we're too cautious or restrictive.
One thing I'm firm on is that event contracts aren't gambling. They serve real economic purposes, like price discovery and risk management, much like other derivatives. Labeling them as "gaming" feels like a misstep to me, and I urge the CFTC to recognize their legitimate value when addressing questions like those in Topic Area C (Questions 15-22) about defining gaming versus legitimate markets. These contracts aren't slot machines; they require research and judgment, just like trading stocks or commodities.
I'm also concerned about the idea of over-restricting or banning these markets. I've read about platforms like Kalshi, which operate under CFTC oversight, and that kind of regulated environment feels far safer than the alternative. If we push too hard with bans, people will just turn to offshore platforms where it's a complete free-for-all. Thats not protecting consumers; its putting them at greater risk. On Topic Area B (Questions 7-14) about balancing innovation and consumer protection, Id argue that proportionate regulation, not broad categorical bans, is the way to go. The CFTC already has strong tools to tackle manipulation and insider trading. Use those instead of shutting things down.
On insider trading specifically, I do think clearer rules are needed. Its a real concern. But again, banning markets isnt the answer. That just drives activity offshore to a wild west with no oversight at all. Lets keep it here, under your watch, with targeted rules to address bad actors.
Im asking the CFTC to support prediction markets with fair, balanced regulation that lets regular people and businesses participate while addressing specific risks. Dont let overreach or outright bans push this innovation out of the US. We can get this right if we focus on oversight, not prohibition.
Thank you for considering my perspective.
Sincerely,
Marc Pedersen
