Comment Text:
Dear Chairman and Commissioners,
My name is Samarth Sudarshana, and Im a student from Maryland. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive used prediction markets a few times myself, and I believe they have real value for individuals like me and for society as a whole. I strongly support regulating these markets in a fair and proportionate way, rather than restricting or banning them.
As a student, Im always looking for reliable information to understand complex events, especially around elections or major public issues. Prediction markets have consistently given me better insights than polls or pundits. The prices reflect what people actually think, based on real stakes, not just opinions. This isnt just helpful for me; its valuable for everyone who wants to cut through the noise and get a clearer picture of what might happen. Beyond that, I value the freedom to participate in legal, regulated markets. Shutting regular people like me out of these platforms would mean only big players get access to this information, and that doesnt seem fair.
I also think its critical that the U.S. stays competitive in financial innovation. If we over-regulate or ban prediction markets, we risk pushing activity to unregulated offshore platforms, which are far less safe. Id much rather see platforms like Kalshi, which operate under CFTC oversight, thrive here in the U.S. On a related note, I believe event contracts serve real economic purposes and shouldnt be labeled as gambling. Ive read about how individuals and businesses use these markets to hedge risks, like protecting against policy changes or economic shifts that could affect their livelihoods. Thats not gaming; its practical decision-making, similar to other kinds of investing.
Looking at some of the specific questions in the ANPR, Id like to address a few points. On Questions 7-14 about public interest, I believe the CFTC should prioritize innovation while ensuring consumer protections, not by banning markets but by enforcing existing rules against manipulation. For Questions 15-22 on listed activities, I urge you not to classify event contracts as gaming. Theyre tools for forecasting and hedging, not games of chance. And on Questions 23-28 about procedures, I think public interest determinations should focus on specific risks, not broad categories, to avoid stifling legitimate markets.
I understand there are concerns about insider trading or manipulation, but those are already illegal under existing laws. The CFTC has the tools to tackle bad actors without punishing everyone else by shutting down these markets. I hope youll consider the benefits prediction markets bring to people like me and to the broader public. Please support proportionate regulation that allows these markets to operate safely and legally in the U.S.
Thank you for considering my input.
Sincerely,
Samarth Sudarshana