Comment Text:
Ladies and Gentlemen of the CFTC,
I wish to comment regarding the proposed rules and their implementation concerning prohibition of gaming with regard to election prediction and the resultant harm this will cause the public should it be applied across the board without regard to distinctions and necessary exceptions that must be considered and given effect.
After having been a "trader" on PredictIt for several years, I have found that the greatest value, by far, achieved by the program is not the incidental and minor gaming that is a necessary part of the program, but rather the enormously credible reports of predictions that are derived therefrom.
PredictIt's predictions have far greater value in my experience than all of the poll taking otherwise done. It's highly likely that poll taking without the underpinning of minor gaming is unreliable and untrustworthy. Nor do I believe that this program would work if there was significant amounts of money involved. In this instance, although the money is incidental, it very much produces decisions on the part of those members involved that are based on their true beliefs concerning the outlook of an election matter, and not a statement by the person being polled that he or she believes the poll taker is seeking. It is literally an arms length transaction not for the purpose of making money but to participate in a process that helps us all to understand the beliefs and views of others regarding such a vital matter.
In conclusion, I urge you to consider a carve out of programs such as PredictIt so as to permit it to continue, not because it is gaming, but because it is a valuable public service.
