Comment Text:
Dear Chairman and Commissioners,
My name is Pierce Goodman, and I'm a student from Texas 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 individuals like me, as well as for society at large. I strongly support proportionate regulation of these markets rather than heavy restrictions or outright bans.
As a student, I've seen firsthand how prediction markets can offer unique insights that you just can't find in polls or news commentary. They've helped me think critically about real-world events and even hedge personal financial risks. For instance, I used a market to gauge potential policy changes that could impact my student loans and part-time job. This isn't gambling, it's a practical tool for managing uncertainty, much like how someone might use futures to hedge against price swings. I believe event contracts serve a legitimate economic purpose and shouldn't be lumped in with gaming, as discussed in your questions 15 through 22 about listed activities.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore alternatives. If we over-restrict or ban these markets, people won't stop trading, they'll just move to less secure venues with no consumer protections. This ties directly to your questions 7 through 14 on public interest. Regulation should focus on keeping activity safe and transparent here in the US, not pushing it out of reach. On top of that, the US should be leading in financial innovation. We shouldn't cede this space to other countries by stifling a growing industry.
I'm not blind to the risks, though. Manipulation and insider trading are real concerns, but the CFTC already has strong tools to address them, as you note in questions 1 through 6 on core principles. There's no need for broad bans when targeted enforcement can handle bad actors. Banning entire categories of contracts, as discussed in questions 23 through 28 on procedural aspects, feels like using a sledgehammer to crack a walnut. Proportionate rules that address specific risks make more sense and still protect consumers.
Prediction markets aren't just for big players. They let regular people like me have a stake in understanding and managing risks tied to elections, economic data, or policy shifts. They're a democratizing force, and with the right oversight, they can thrive safely. I urge the CFTC to support well-regulated prediction markets with targeted, fair rules that keep innovation alive while protecting the public.
Thank you for considering my perspective.
Sincerely,
Pierce Goodman
