Comment Text:
Dear Commissioners,
My name is Andrew, and I've been an active participant in prediction markets for some time now. I'm writing because I care deeply about how these markets are regulated, and I believe the CFTC has an opportunity to get this right.
For me, prediction markets have become an indispensable tool. When I'm trying to assess the likelihood of an election outcome, a policy shift, or a major economic event, the prices on these platforms consistently prove more reliable than polls, pundits, or cable news narratives. That accuracy isn't coincidental it's the product of real people putting real capital behind their best judgment. The result is a form of crowd-sourced intelligence that benefits not just traders like me, but journalists, researchers, policymakers, and the general public.
I want to speak directly to the question of whether event contracts constitute gaming specifically, Question 15 in the ANPRM. In my view, the answer is clearly no. These contracts function the way any other financial instrument does: they allow participants to hedge against uncertainty and they surface genuine price discovery. A farmer buying futures to lock in a crop price and a trader buying an event contract to hedge against political risk are engaged in fundamentally the same activity. Labeling one as legitimate and the other as gambling would be an arbitrary distinction that ignores economic reality.
It's worth noting that a similar logic applies to sports markets. When someone analyzes team performance data, injury reports, and matchup history to take a position on a game outcome, they are engaging in skilled analysis and risk assessment not pulling a slot machine lever. The presence of skill, research, and informed decision-making is what separates a market from a casino. Sports-linked contracts, like other event contracts, can serve genuine hedging purposes consider a business whose revenue depends on a local team's season performance, or a media company with advertising exposure tied to playoff outcomes. Dismissing these markets as gambling overlooks their real economic function.
I won't pretend there are no risks. Manipulation and insider trading are legitimate concerns in any market, prediction markets included. But the appropriate response is targeted enforcement, not wholesale prohibition. We didn't shut down equity markets after Enron, and we shouldn't strangle prediction markets over hypothetical abuses. The CFTC already possesses robust enforcement authority the task is to apply and adapt those tools to this new asset class, not to abandon the asset class altogether.
I urge the Commission to pursue regulation that is proportionate and forward-looking. Clear rules that protect consumers, ensure market integrity, and hold platforms accountable without smothering the innovation that makes these markets valuable in the first place.
Thank you for considering my perspective.
Respectfully,
Andrew
