Comment Text:
Dear Chairman and Commissioners,
My name is Steven Ching, and I'm a small business owner from California. I'm writing to you about 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 proportionate regulation. They've already made a huge difference in my life, and I want to share why I think theyre valuable, not just for me but for many others like me.
Running a business comes with constant uncertainty, especially with economic shifts, policy changes, and even unexpected events like weather disruptions. Prediction markets have been a lifeline for me in managing some of that risk. Theyve saved me from financial ruin, not through luck, but by helping me be more strategic at the right times. For instance, Ive used these platforms to hedge against potential policy changes that could impact my supply costs. That kind of foresight isnt gambling. Its a practical tool, much like any other financial instrument I might use to protect my livelihood.
I also want to stress that event contracts shouldnt be classified as gaming. They serve real economic purposes, like hedging risks for people like me who dont have the deep pockets of big institutions. This isnt about rolling dice. It takes research and judgment to participate, just like investing in stocks or commodities. Calling it gaming feels like a misstep that could unfairly shut down a useful market. On top of that, prediction markets level the playing field in a way the stock market often doesnt. Instead of riding the waves controlled by big money, Im on a platform where statistics and actual intelligence matter. Its a true equal opportunity space to engage with peers, not just follow the whims of Wall Street giants.
Ive looked at some of the questions in your ANPR, particularly those in Topic B about public interest (Questions 7-14) and Topic C about listed activities (Questions 15-22). On public interest, I believe prediction markets balance innovation and consumer protection when regulated sensibly. They provide unique information through price discovery that benefits everyone, not just traders. On the gaming question, I urge you to define these contracts by their economic utility, not lump them in with entertainment or chance-based activities. Theyre about managing real-world risks.
I know there are concerns about manipulation or insider trading. I get that. But those issues are already illegal, and the CFTC has tools to address bad actors without banning entire markets. Shutting down prediction markets to stop a few cheaters would hurt small players like me who rely on them for legitimate reasons.
I ask you to support proportionate regulation of prediction markets. Dont over-restrict or ban them. Keep them accessible for regular people and businesses while using your existing authority to tackle any misuse. Thank you for considering my perspective.
Sincerely,
Steven Ching
