Comment Text:
Comment for Proposed Rule 91 FR 12516
April 24, 2026
Michael S. Selig
Chairman
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, NW
Washington, DC 20581
Dear Chairman Selig:
I write with an urgent request. The Commodity Futures Trading Commission must take action to protect our children from harmful gambling-like behavior – and eliminate the sports event contracts offered by prediction markets.
As the ultimate moms support group, it is our obligation at Moms for America to enhance the futures of all of our children and grandchildren.
Prediction markets threaten that future, luring in millions of teenagers too young to step into a Las Vegas casino by presenting unsafe sports betting sites as legitimate investment. Using a deceptive format that appears legitimate and accessible, prediction markets tied to sports outcomes risk exposing young adults – and even underage users – to gambling-like behavior.
A recent national survey(1.) found that nearly two thirds of adults ages 21 and older (65%) reported participating in at least one form of gambling before age 21.
Their focus: sports. One third of 21–44-year-olds placed a sports bet before age 21, versus 11% of people 55 and over.
For these youthful bettors, prediction markets mean gambling. The survey found that 30% of Americans said that prediction market platforms are most similar to gambling — the most common response — compared to 18% who said investing. And by allowing prediction markets to aggressively market sports betting to users as young as 18, the CFTC is enabling addictive behavior without any of the appropriate safeguards that come with licensed sports betting.
Prediction markets are far from passive observers of these trends. As The Wall Street Journal illustrated in a recent expose, prediction market platforms have descended onto college campuses, created a “campus frenzy”(2.) through shady marketing aimed at reeling in customers.
Both the Kalshi and Polymarket platforms have been paying student influencers and creators on TikTok and Instagram to promote them, the Journal reported, while Polymarket has offered to help fund parties for fraternities in exchange for signing up users.
That’s because the platforms are taking advantage of a three-year window to target the 18- to 20-year-old crowd, created by a loophole in the regulatory landscape. The CFTC is allowing prediction markets to rebrand their gambling activities as “trading,” or “investing” — meaning that people as young as 18 can wager nationwide, even in the states where online sports gambling remains illegal.
And most states with legal online sports betting restrict it to people 21 and older
Using its regulatory authority and credibility, the CFTC needs to step in to eliminate sports event contracts altogether– and prevent these platforms from becoming a gateway to early sports betting addiction.
Sincerely,
Emily Stack
(1.) https://www.ncpgambling.org/news/survey-finds-widespread-gambling-participation-before-age-21/#:~:text=Played%2520fantasy%2520sports%2520(16%2525),are%2520protected%2520from%2520early%2520exposure.%E2%80%9D
(2.) https://www.wsj.com/business/media/prediction-markets-campus-e57cd19f
