Comment Text:
Dear Chairman and Commissioners,
My name is Francis Capulong, and I'm a software engineer based in California. I work in tech, where data and forecasting are everything, and I've used prediction markets a few times to get a better read on events like elections or policy shifts that impact my industry. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to urge the CFTC to support proportionate regulation of these markets rather than banning or over-restricting them.
I value prediction markets because they provide information that's hard to find elsewhere. As someone who crunches data for a living, I can tell you that the aggregated forecasts from these platforms often beat out polls or pundit opinions. That kind of insight isn't just useful for traders like me; it helps the public and even policymakers make better decisions. Plus, I've used these markets to hedge personal financial risks tied to public events, like potential regulatory changes that could affect tech hiring or project funding. This isn't gambling. It takes research and judgment, much like any other investment.
I'm also concerned about freedom and fairness. Prediction markets let regular people like me participate in a space that would otherwise be dominated by big institutions. And from a tech perspective, I believe the US should be leading in financial innovation. If we over-restrict these markets, we're just ceding ground to other countries. Worse, banning or heavily limiting them will push activity to unregulated offshore platforms, which are far riskier for consumers. I've seen how regulated markets like Kalshi operate with transparency and oversight. That's the kind of environment I want to participate in, not some sketchy offshore site.
I appreciate that the CFTC is asking tough questions about manipulation and insider trading in this ANPR, especially in Topic Area A (Questions 1-6) and Topic Area E (Questions 29-32). But I want to point out that the CFTC already has strong tools to tackle these issues in other derivatives markets. Those same tools can be adapted here. Shutting down or over-regulating prediction markets to stop a few bad actors feels like punishing everyone else. We don't shut down stock markets over insider trading; we enforce the rules. The same logic should apply.
I also want to touch on Topic Area B (Questions 7-14) about public interest. Prediction markets aren't just about individual gain. They improve price discovery and give us better data to understand the world. Academic research backs this up, showing how these markets aggregate information efficiently. They serve real economic purposes, not just entertainment.
I urge the CFTC to regulate prediction markets in a balanced way. Address specific risks with targeted rules, but don't ban or overly restrict them. Keep the US competitive, protect consumers with oversight, and let people like me continue to access these valuable tools.
Thank you for considering my input.
Sincerely,
Francis Capulong
