Comment Text:
The proposed rule defining election futures markets like PredictIt's as "gaming" should not be adopted for several reasons.
First, while "gaming" has a number of meanings, in this context it means playing a game of chance. Prediction markets are NOT games of chance. For users (like me), they provide a fun way of getting me to evaluate important political issues as objectively as possible. Political markets are not games of chance - they are opportunities to think through how groups of people evaluate candidates and issues as relevant environments change. That is as different from a roulette wheel (an actual game of chance) as a Porsche 911 is from a VW Beetle (even if both were substantially invented by Dr. Porsche). The activity is, simply put, not "gaming" and so it should not be treated as if it were. We should not incorrectly define things when we are charged with regulating them.
Second, adopting an erroneous definition resulting in termination of the ability to participate in election futures markets as enabled by PredictIt would have negative effects. I use Predict-It's election futures prediction markets as a fun way to think deeper about elections than simply identifying outcomes or candidates I prefer. It makes me take other people's concerns into account, something we should all do more of, not less. Especially in a time when people are concerned with the effects of "fake news," these election prediction markets provide needed education into helping us all become better at digging past political social media manipulation into a more thoughtful and honest evaluation of facts.
Third, adopting an erroneous definition resulting in termination of the ability to participate in election futures markets as enabled by PredictIt would have no positive effects. PredictIt has embedded low trade caps to eliminate domination by the wealthy and the trade values are so low that their value lies not in making money by gambling (i.e., "gaming") but in digging deeper into current political issues.
Fourth, adopting an erroneous definition resulting in termination of the ability to participate in election futures markets would also have the negative effect of depriving us of the ability to permit researchers access to anonymized trade data to better understand human decision-making, and particularly political decision-making, to the benefit of all of us.
That is, there are many reasons that the CFTC should NOT adopt a rule defining PredictIt's election futures markets as "gaming" and hence unavailable to the public ranging from simple accuracy of concept to the public good.
