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Comment for Proposed Rule 89 FR 48968

  • From: David Nicponski
    Organization(s):
    none

    Comment No: 74276
    Date: 8/7/2024

    Comment Text:

    Hello,

    As a long-time PredictIt user, I find the proposed classification of the prediction market as "gaming" to be problematic and misguided.


    Prediction markets are a useful tool to gauge market estimates of risk and likelihood of inherently stochastic future events, and provide a valuable tool for both market participants and people who require broad and robust estimates of probabilities associated with various future possible events.

    I strongly urge that this proposal be changed.

    To repeat some points from predictit themselves:

    PredictIt is approaching its 10 year anniversary, making it one of the biggest and longest running prediction markets in American history.

    PredictIt trades are capped at $850 per user per contract. This helps to keep the market small-scale and ensures that wealthy individuals cannot manipulate markets. This protects the sanctity of the crowdsourcing process, and differentiates PredictIt from other financial markets that are dominated by hedge funds and institutional investors.

    In its 10 year history, PredictIt has made these crowdsourced probabilistic forecasts available to the public, and makes anonymized trade data available to researchers who study patterns in the data.

    Research shows that these forecasts are generally accurate and are generally more accurate than polling, especially earlier in a race. This is because polls are a snapshot in time, but prediction markets allow users to weigh the effect of factors (the criminal conviction of a presidential candidate, for example) that have not yet fully resonated with voters.

    Because of its accuracy, PredictIt data is widely cited by media, campaigns, and financial institutions, and even appears on the Bloomberg Terminal.

    The research also shows that PredictIt makes users more likely to seek out factual information about current events. Users who build trading strategies around factual events tend to do better than those who trade based on their ideologies or misinformation. In an era where both liberal and conservative commentators are alarmed at the public’s acceptance of fake news and misinformation, these markets are one of the few mechanisms left for incentivizing the accumulation of true and accurate information (an antidote to fake news).

    Despite the inherent public good that these markets offer, the CFTC is currently on the warpath against prediction markets. The CFTC is both aiming to shut down PredictIt (and has repeatedly been stopped by courts, including the second highest court in the land) and is proposing a rule that would ban election markets in the United States, perhaps permanently.

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