Comment Text:
Dear Chairman and Commissioners,
My name is Eric Chung, and I'm a student from Washington state. I'm 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). As someone who actively trades on platforms like Kalshi and Polymarket, I've seen firsthand the value these markets provide, not just to me but to society as a whole. I believe the CFTC should craft rules that encourage innovation and protect consumers without over-restricting or banning these markets.
Prediction markets are an incredible tool for forecasting. I've watched them outperform polls and pundits time and again on election outcomes and major public events. That kind of accurate information isn't just useful for traders; it's valuable for everyone, from journalists to policymakers. Beyond forecasting, these markets let me hedge personal financial risks. For instance, I've used them to offset uncertainties around economic events that could impact my student budget or future career prospects. This isn't gambling. It takes research and real-world judgment, much like any other investment.
I'm also a big believer in freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore alternatives. If the U.S. bans or over-restricts prediction markets, activity will just move to less secure venues, putting consumers at greater risk. The U.S. should lead in financial innovation, not cede ground to other countries. As a student, I also value the academic side. Prediction markets provide transparent data for research, and informed trading improves price discovery, benefiting everyone in the market.
Addressing some of your specific questions, like those in Topic Area B (Questions 7-14) on public interest, I believe the CFTC should prioritize balancing innovation with consumer protection by focusing on proportionate rules, not broad bans. On Topic Area C (Questions 15-22) regarding listed activities, event contracts shouldn't be classified as gaming. They serve legitimate economic purposes like hedging and price discovery. And on Topic Area E (Questions 29-32) about inside information, I think the CFTC already has robust tools to tackle manipulation and insider trading. Use those instead of punishing all participants with heavy-handed restrictions.
One last thought: I'd love to see the CFTC allow hedging on live contracts for assets like Bitcoin. It would help regular people manage volatility in emerging markets. Please support prediction markets with targeted, fair regulation that keeps them accessible and safe. Don't let overregulation push innovation and opportunity overseas.
Thank you for considering my perspective.
Sincerely,
Eric Chung
