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Comment for Proposed Rule 91 FR 12516

  • From: Drew Musson
    Organization(s):
    Private citizen

    Comment No: 115060
    Date: 4/23/2026

    Comment Text:

    Prediction markets, if they must exist, should be regulated similarly to stocks, bonds, futures and etc. The concept is even more susceptible to manipulation by people with insider knowledge of any event, making someone's "prediction" a guarantee. This has already been shown to be true and is being actively exploited. Without rules against it, people will actively seek out ways to influence the outcome of events. Drawn to its logical conclusion, no outcome is what would have occurred had there not been monetary incentive informing said outcome.

    The idea that these markets are a more accurate data collection options makes sense until one analyzes the data. Sufficiently large enough bets have been shown to influence the market in the direction of those large bets. That no longer represents the true thoughts or choices of the people choosing to participate. That in turn makes the data less accurate or useful.

    Another discussion point is the current decision model employed using crowd sourced opinion via universal market access (UMA). The premise is that people can vote on whether a specific outcome met the criteria of the "prediction" or if it didn't. Seems fair on the surface. The issue is that each vote is cast via a digital token that must be purchased before use. As with many things, the issue lies in that certain people are able to obtain more of these digital tokens than others by having more money. That, in turn, allows them to cast more votes, presumably in favor of the outcome that person prefers. This allows people with more available funds to decide the outcome of a "prediction", even if it is demonstrably false. Anyone with sufficient wealth is therefore theoretically guaranteed their desired outcome.

    Lastly, it cannot be ignored that these prediction markets are, at a minimum, gambling adjacent. Legal loopholes aside, these markets feed into the same addictive behavior and can lead to similar, if not identical, negative consequences for those individuals who suffer from gambling addiction. Gambling is regulated because it can cause serious harm. Legal distinctions are not something that will stop people from abusing these markets; it will only enable the behavior.

    I implore this governmental entity to enact regulations to curtail the abuses already prevalent in these prediction markets. If they must exist, regulations to ensure the data generated is accurate is a benefit. However, the biggest benefit would be at least the concept of fairness hinted at by the regulations of other financial markets.

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