Comment Text:
Dear Chairman and Commissioners,
My name is Cam Huynh, and I'm an everyday citizen from Washington state writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've used prediction markets a few times myself, and I strongly support their existence under fair, proportionate regulation by the CFTC. I believe these markets provide unique value to people like me, to businesses, and to society as a whole, and I want to explain why I think the CFTC should regulate them thoughtfully instead of restricting or banning them.
First off, prediction markets give us information thats hard to find anywhere else. Ive seen how their forecasts on elections and public events often beat out polls or pundits. That kind of accuracy helps me make sense of whats happening in the world, and I think its valuable for everyone, not just traders. Beyond that, these markets let regular people like me participate in a system thats usually reserved for big institutions. Keeping them open to everyday citizens feels fair and actually makes the predictions better by bringing in more perspectives. Ive also come to see them as a tool for hedging real risks. For instance, Ive thought about using them to offset uncertainties tied to policy changes that could affect my personal finances. This isnt gambling to me. Its about research and judgment, much like any other investment.
Im also worried about what happens if these markets get over-restricted. Platforms like Kalshi, which are regulated by the CFTC, feel safe and transparent. If rules get too tight, people will just turn to unregulated offshore sites, which are riskier for consumers. The U.S. should be leading the way in financial innovation, not pushing it overseas. Plus, theres solid academic research showing how prediction markets improve information and price discovery. Informed trading, even if its by people with a lot of knowledge, benefits everyone by making prices more accurate.
I know there are concerns about manipulation or insider trading, and I get that. But the CFTC already has strong tools to tackle those issues in other markets, and I believe those can be applied here too. Banning or heavily restricting prediction markets punishes honest participants instead of targeting bad actors. Id urge you to look at specific questions in the ANPR, like Question 7 on balancing innovation and consumer protection, and Question 15 on defining gaming versus legitimate markets. I strongly believe event contracts serve real economic purposes like hedging and forecasting, not gambling, and should be treated as such. Questions 29 and 30 on inside information also matter to me, as I think informed trading helps, not hurts, the markets value to the public.
In short, I ask the CFTC to support proportionate, targeted regulation of prediction markets. Dont ban or over-restrict them. Focus on specific risks with the tools you have, and keep these markets accessible, safe, and innovative for people like me.
Sincerely,
Cam Huynh
