Comment Text:
Dear Chairman and Commissioners,
My name is Sergey Dudkin, and I'm a student based in New York. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I believe they have real value for society, especially when regulated properly. I'm asking you to support proportionate rules that allow these markets to thrive while addressing specific risks, rather than imposing broad bans or overly restrictive policies.
As a student, I'm always looking for better ways to understand the world around me. Prediction markets have been eye-opening because they provide information you can't get from polls or news pundits. The prices reflect what people actually think will happen, based on their research and judgment, and I've seen firsthand how this can cut through noise and bias. This isn't just helpful for traders; it benefits everyone by improving public decision-making and price discovery. I think this aligns with the CFTC's questions 7 and 8 in the ANPR about the public interest and the role of these markets in providing useful information.
I also strongly believe that regular people like me should have the freedom to participate in legal, regulated markets. Banning or over-restricting prediction markets won't stop them; it will just push activity to unregulated offshore platforms where there's no oversight. That seems like a step backward. The US has a chance to lead in financial innovation here, setting a global standard for how these markets should work. Why should we cede that opportunity to other countries? This ties into question 14, where you ask about balancing innovation and consumer protection. I think we can have both with smart, targeted rules.
On the concern about insider trading or manipulation, raised in questions 29 to 32, I understand the worry. But informed trading often improves price discovery, making the market more accurate for everyone. Plus, laws already exist to punish insider trading and manipulation. The CFTC has the tools to enforce those rules without shutting down entire markets. Broad categorical bans punish honest participants and don't solve the root issues. Targeted regulation, focusing on specific risks, would be far more effective.
I've used prediction markets to better understand political and economic events, and I want to keep that opportunity. These platforms encourage me to think critically and engage with real-world issues. Please don't take that away with heavy-handed restrictions. I urge you to craft rules that protect consumers while allowing prediction markets to grow under CFTC oversight.
Thank you for considering my perspective.
Sincerely,
Sergey Dudkin
