Comment Text:
Dear Chairman and Commissioners,
My name is Max Zuniga, and I'm an everyday citizen from Arizona 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 existence under fair and reasonable regulation. I believe these markets offer unique value to people like me, and I want to see the CFTC craft rules that protect consumers without shutting down this innovative tool.
As someone who values the freedom to participate in legal, regulated markets, I see prediction markets as a way to access information and manage financial risks in my personal life. For instance, being able to hedge against economic or policy changes that might affect my budget, like a shift in tax rates or inflation data, feels empowering. It's not gambling. It's about making informed decisions, just like investing in stocks or mutual funds. I also appreciate that academic research backs this up, showing how these markets aggregate information better than polls or pundits. That kind of transparency benefits everyone, not just traders.
I'm especially concerned about the alternative if the CFTC over-restricts or bans these markets. I've read about platforms like Kalshi, which operate under CFTC oversight, and they seem far safer than unregulated offshore sites. If we push this activity offshore with heavy-handed rules, people like me lose the protection of U.S. regulation. Banning or overly restricting prediction markets doesn't stop them; it just makes them riskier. The CFTC already has strong tools to fight manipulation and insider trading in other markets. I trust those can be adapted here without resorting to broad categorical bans. Targeted, proportionate regulation makes more sense.
Regarding some of the specific questions in the ANPR, I want to address Question 7 on balancing innovation and consumer protection. I think regulated markets strike that balance by keeping activity under your oversight while allowing informed trading to improve price discovery, which helps everyone. On Question 15 about listed activities, I do believe there should be limits. I'm uncomfortable with markets on sensitive topics like a politician's death, natural disasters, or war events. But contracts on less personal matters, like when a politician leaves office, seem reasonable to me.
I support regulation, but it needs to be fair and focused. Please don't punish regular folks by over-restricting prediction markets. Keep them legal, safe, and accessible under CFTC oversight. I'm counting on you to get this right for people like me in Arizona and across the country.
Sincerely,
Max Zuniga
