Comment Text:
Dear Chairman and Commissioners,
My name is Marc Vergara, and Im a trader and investor based in Texas. Ive been actively trading on prediction markets like Kalshi and Polymarket for a while now, and Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to people like me, and to society as a whole, and I urge the CFTC to adopt proportionate regulations rather than overly restrictive rules or outright bans.
As a trader, Ive seen firsthand how prediction markets offer information you cant get anywhere else. Their forecasts on elections and major public events consistently beat polls and pundits. Ive used these insights to make better decisions, not just in trading but in understanding the world around me. This isnt just about profit for a few. Accurate price discovery helps everyone, from regular folks to policymakers, by shedding light on whats likely to happen. I also rely on these markets to hedge personal financial risks tied to things like policy changes or economic shifts. For example, Ive traded contracts related to interest rate decisions to offset risks tied to my investments. This isnt gambling. Its research and judgment, no different from trading stocks or commodities.
Im also concerned about what happens if the CFTC over-restricts or bans these markets. Right now, platforms like Kalshi operate under CFTC oversight, which makes them safer for traders like me with rules and transparency. If you clamp down too hard, activity will just move to unregulated offshore platforms where theres no protection at all. Ive traded on Polymarket too, and while its useful, the lack of oversight there is a real risk. Keeping these markets regulated in the U.S. is the better path. Plus, the U.S. should be leading in financial innovation. We shouldnt cede this space to other countries by making it too hard for legitimate platforms to operate here.
On specific issues in the ANPR, I want to address Question 15 about defining gaming versus legitimate markets. Event contracts arent gambling. They serve real economic purposes like hedging and price discovery. Classifying them as gaming would be a mistake, just like calling stock trading gaming would be. And on Questions 7 and 8 about public interest and innovation, I believe the CFTC can balance consumer protection with fostering growth by focusing on targeted rules against manipulation or insider trading, not broad bans. Existing laws already cover these bad actors. Dont punish the rest of us by shutting down a valuable tool.
I ask the CFTC to support prediction markets with fair, proportionate regulation. Lets keep these markets safe and accessible here in the U.S. without over-restricting them or pushing activity offshore. Thank you for considering my perspective.
Sincerely,
Marc Vergara
