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Comment for Proposed Rule 91 FR 12516

  • From: Jonah Campbell-Shinault
    Organization(s):
    Individual

    Comment No: 114983
    Date: 4/22/2026

    Comment Text:

    Time and time again, the CEO's of companies such as Polymarket or Kalshi have gone on record stating that their platforms aren't gambling. They claim that these are platforms for "truth", that they predict events more accurately because of the masses of people staking real money on the outcomes of real life events. From betting on colors of ties to missile from drones, these platforms have proven that these platforms could be predictive, but not for the reasons stated by their CEO. These platform embrace insider trading with open arms, because it's not gambling, you see. The reasoning given by Brian Armstrong (CEO of Coinbase) in a now famous interview with The New York Times, "if your goal is to actually for the 99% of people trying to get signal about what's going to happen in the world, like is the Suez Canal going to be reopened or whatever, you actually want insider trading." and then immediately goes on to say "Now, if you want to preserve the integrity of those markets, maybe you don't want insider trading". His position being that sometimes it's important for these markets to be manipulated by people with insider knowledge, but by allowing that you are compromising the integrity of those markets. Prediction markets have decided that not only is insider trading allowed, but now with tools such as UMA protocol (a blockchain DAU used by companies including Polymarket) decide whether or not the results of a prediction market are "true". So say you, the individual reading this, make a bet on Polymarket (random example) whether Volodymyr Zelensky will show up to an event in a suit or not. You vote yes, which has a majority share, but he ends up coming in clothing that, for one reason or another, is suit agnostic. Well, in this case, it doesn't matter if someone had knowledge of Zelensky's clothing and voted yes ahead of time, because now and entire separate entity from the market you voted on and Polymarket itself is now in charge of deciding whether Zelensky's outfit was a suit or not, this being the UMA protocol. This situation is real, actually happened, and the protocol voted no. These markets are not predictive, they are prescriptive. Anybody with enough money can decide what the outcome is, either through enough shares in a prediction, or though a 3rd party platform such as UMA. There is zero integrity with these systems. There is no freedom or truth for the common man. This is in an insider trading scam more blatant then we've ever seen, and it will eventually poison the reputation of anyone that touches it. We know that ex-employee's of CFTC work with these companies, and when public opinion of prediction markets goes the way of crypto it will drag CFTC's reputation down with it unless you do something about it now. Thank you for reading, end these markets.

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