Comment Text:
Dear Chairman and Commissioners,
My name is Jason Molina, and I'm a trader and investor based in New York. I've been following markets for years, and Ive dabbled in prediction markets a few times to get a sense of how they work. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets, and I want to share why I think the CFTC should focus on sensible rules rather than heavy-handed restrictions.
As someone who spends a lot of time analyzing data and trends, Ive come to value prediction markets for their ability to forecast outcomes, especially for elections and major public events. I've seen firsthand how the aggregated wisdom of these markets often beats out polls or talking heads on TV. A few years back, I used a platform to track sentiment on a presidential election, and the probabilities there were far closer to the actual result than anything I saw in the news. That kind of insight is valuable not just to traders like me, but to anyone trying to understand whats coming next in our world.
What worries me is the idea of pushing these markets underground. I've looked at platforms like Kalshi, which operate under CFTC oversight as a designated contract market, and then I've seen the offshore, unregulated sites that pop up when rules get too tight. The difference in safety and transparency is night and day. Regulated markets have accountability, clear rules, and protections against fraud or manipulation. Offshore platforms? Good luck if something goes wrong. Banning or over-restricting prediction markets here in the US would just drive activity to those shadier corners of the internet, and I don't think that's in anyone's interest.
I also want to touch on a couple of the specific questions you raised in the ANPR. Regarding Question 7 on balancing innovation and consumer protection, I think regulation should focus on transparency and anti-manipulation measures, not outright bans on certain contracts. And for Question 29 about inside information, I believe the CFTC already has tools to address insider trading in other markets, and those can be applied here without shutting down the whole system. Punish the bad actors, not the rest of us who are using these markets legitimately.
Prediction markets aren't perfect, and I get the concern about potential abuse. But the answer isn't to clamp down so hard that only big institutions or offshore players can operate. Regular people like me benefit from access to this information, and were better off with regulated platforms we can trust. I urge the CFTC to craft rules that support innovation while addressing specific risks with targeted solutions.
Thank you for considering my input. I hope you'll move forward with proportionate regulation of prediction markets and avoid overly restrictive measures.
Sincerely,
Jason Molina