Comment Text:
Dear CFTC,
I am writing to express my strong opposition to the proposed rule entitled "17 CFR Part 40 Event Contracts." This proposal would effectively ban individuals in the United States from participating in election futures markets, such as PredictIt, by defining these markets as "gaming." This characterization is misguided and fails to recognize the valuable role that prediction markets play in our political process.
First, the CFTC does not have any duty or obligation to regulate elections or their results. The proposal seems, by my read, to be driven by the CFTC’s concern that it could be called to police potential market manipulation in some possible future, and that it generally does not wish to do so. I would like to remind the CFTC that this is not a realistic concern nor is it a valid reason to try to ban election prediction markets in the United States. Elections are run by a multitude of state and local entities that have a diverse collection of systems, monitors, and checks in place to prevent such manipulation from occurring in the first place. The CFTC's focus should be on setting clear and enforceable rules for the market, rather than imposing an outright ban.
Second, the proposal infringes on my rights to engage in political activity. By preventing individuals from participating in election futures markets, the CFTC is limiting our ability to express our political opinions and engage in political discourse. This is an unconstitutional infringement on our rights as American citizens.
Third, recent history has shown that traditional political polling methods involving landline telephones or surveys are often inaccurate and skewed. They have very large margins of error. In contrast, prediction markets have proven to be far more accurate at forecasting election results. These markets provide valuable information that informs political organization activity and speech, and they should be allowed to continue to operate.
In conclusion, I urge the CFTC to reconsider this proposal and to recognize the important role that election futures markets play in our political process. They are not 'gaming' but are an important form of political expression and research discovery. Banning election event contract markets would be a grave disservice to the public and to our democracy. In short, the CFTC should regulate markets and ensure a level playing field by setting reasonable rules. The proposed rules are not reasonable. This proposal should be struck from consideration and should not be implemented.
Sincerely,
Matthew Ivan
