Comment Text:
Dear Commodity Futures Trading Commission,
I am writing to express my strong opposition to the proposed rule that would classify election futures markets like PredictIt as "gaming" and effectively ban them in the United States. As a participant in these markets, I believe this proposal is misguided and fails to recognize the significant value these platforms provide.
PredictIt has operated for nearly a decade, establishing itself as one of the most prominent and long-running prediction markets in American history. Its model of crowdsourced probabilistic forecasting has proven to be a valuable tool for researchers, media outlets, financial institutions, and the general public.
Several key points demonstrate why PredictIt and similar markets should not be classified as gaming:
1) Accuracy and public benefit: Research has shown that these markets often provide more accurate forecasts than traditional polling, especially early in election cycles. This accuracy stems from participants weighing various factors that may not yet be reflected in polls. As a result, PredictIt data is widely cited by media, campaigns, and even appears on the Bloomberg Terminal.
2) Promoting factual information: Studies indicate that participation in these markets encourages users to seek out factual information about current events. In an era of increasing concern about misinformation, these platforms incentivize the accumulation and use of accurate information.
3) Research value: PredictIt makes anonymized trade data available to researchers, contributing to our understanding of political forecasting and decision-making.
4) Responsible limits: The $850 cap per user per contract ensures that the market remains small-scale and prevents manipulation by wealthy individuals or institutions.
5) Educational impact: Participation in these markets can increase engagement with and understanding of political processes and current events.
Classifying these markets as mere "gaming" ignores the time, research, and informed decision-making that participants invest in their trades. Unlike sports betting or roulette, success in these markets is largely based on knowledge and analysis of complex political and social factors.
I urge the CFTC to reconsider this proposal and recognize the unique value and public good offered by election futures markets like PredictIt. These platforms serve as important tools for forecasting, research, and public engagement with the political process. Banning them would be a significant loss for public discourse and our understanding of political dynamics.
Thank you for your consideration.
Sincerely,
W.D. Amstutz
646-701-3526 (text/talk)
