Comment Text:
Dear Chairman and Commissioners,
My name is Christian Brown, and I'm an everyday citizen from Washington state 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've been following their growth with interest, and I strongly support their development under fair and proportionate regulation by the CFTC.
I believe prediction markets offer something valuable that we don't get elsewhere. They provide better information for public decision-making through price discovery. I've seen how often polls and pundits get things wrong, especially around elections or big public events. Prediction markets, on the other hand, seem to cut through the noise with forecasts that are often more accurate. That kind of insight shouldn't just be for big institutions; regular people like me should have access to it too. Plus, participating in these markets feels like a form of freedom, a way to engage with the world in a legal, regulated space.
I also want to push back on the idea that event contracts are just gambling. To me, they serve real economic purposes. Trading on these markets takes research and judgment, much like investing in stocks. It's about understanding real-world events, not rolling dice. I think the CFTC should recognize this distinction and avoid over-restricting something that has clear value for forecasting and civic engagement.
I'm aware there are concerns about manipulation or insider trading, and I get why those are issues. But the CFTC already has strong tools to address these problems in other markets. I believe those same tools can work for prediction markets without needing broad bans or heavy-handed rules. Banning or over-restricting these markets won't stop bad actors; it'll just push activity to unregulated offshore platforms where there's no oversight at all. Regulated markets like Kalshi are far safer, and the US should be leading in this kind of financial innovation, not letting other countries take the reins.
I'd like to address a couple of specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think the focus should be on smart rules that protect users while still allowing new ideas to grow. And on Question 15, regarding defining gaming versus legitimate markets, I urge the CFTC to see event contracts as economic tools, not games of chance.
In closing, I ask that the CFTC support proportionate regulation of prediction markets. Don't ban or over-restrict them. Keep them accessible to everyday people like me under a framework that ensures safety and fairness. Thank you for considering my perspective.
Sincerely,
Christian Brown
