Comment Text:
Dear Chairman and Commissioners,
My name is Kontessa Payne, and I'm an everyday citizen from New York 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 come to believe they have real value for people like me and for society as a whole. I want to urge the CFTC to support well-regulated prediction markets instead of banning or over-restricting them.
I first got interested in prediction markets because Ive seen how often polls and pundits get things wrong, especially with elections and big public events. I remember being frustrated during the last election cycle, trying to figure out what was really going on, and finding that prediction market prices often cut through the noise better than anything else. That kind of forecasting accuracy isnt just helpful to traders. Its useful to everyone who wants to understand the world, from regular folks like me to journalists and even policymakers. I think thats a public good worth protecting.
I also believe strongly in the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, seem far safer than unregulated offshore sites. If the CFTC bans or puts too many restrictions on prediction markets, I worry that activity will just get pushed to those less safe places where theres no oversight at all. That doesnt protect anyone. It just makes things riskier. Id much rather see the US lead the way in financial innovation, setting a standard for how these markets can work responsibly, instead of letting other countries take the lead while we fall behind.
Another concern I have is the idea of classifying event contracts as gaming. I dont see it that way. These markets serve real economic purposes, like helping people hedge against uncertainty or discover better information through trading. Informed traders actually improve price discovery, and that benefits everyone in the market, not just themselves. I think the CFTC should look at this in Questions 15 through 22 about listed activities and gaming definitions, and also Questions 29 through 32 on inside information. The focus should be on targeted rules for specific risks, not broad labels that could shut down legitimate activity.
Im not ignoring the potential for bad actors. I know insider trading and manipulation are real concerns. But those are already illegal, and the CFTC has tools to go after people who break the rules. Shutting down entire markets to stop a few cheaters feels like punishing everyone for something most of us arent doing.
I hope the CFTC will support proportionate regulation that allows prediction markets to thrive under clear, fair rules. Lets keep this innovation in the US, keep it safe, and keep it accessible to regular people like me. Thank you for considering my perspective.
Sincerely,
Kontessa Payne
