Comment Text:
Dear Chairman and Commissioners,
My name is Crystal Benavidez, and I'm just an everyday citizen from South Carolina. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been trading on platforms like Kalshi and Polymarket for a while now, and I strongly support the idea of well-regulated prediction markets in the United States.
I got into prediction markets because I wanted better information to understand what's happening in the world. Polls and news outlets often get things wrong, but the prices on these markets cut through the noise. They're not perfect, but they've helped me make sense of elections, economic trends, and even local weather risks that affect my family. I believe this kind of price discovery isn't just good for me, it's good for everyone, from regular folks to policymakers who need reliable data. Plus, trading on these platforms isn't gambling. It takes research and real judgment, just like investing in stocks. Labeling event contracts as "gaming" feels like a misstep to me, since they serve real economic purposes like hedging risks or gaining insight.
I'm also worried about what happens if we over-restrict these markets. I've seen unregulated offshore platforms out there, and they're nowhere near as safe as a regulated market like Kalshi, which operates under CFTC oversight. Pushing activity to those shady corners of the internet doesn't protect anyone, it just makes things riskier. The CFTC already has strong tools to tackle manipulation and insider trading in other markets. Why not use those same tools here instead of broad bans? And let's not forget that informed trading actually helps. When knowledgeable people participate, the prices get sharper, and that benefits all of us.
I'd like to address a couple of specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think the US has a chance to lead in financial innovation. We shouldn't let other countries take the lead by over-regulating here. And on Question 15, regarding defining gaming versus legitimate markets, I urge you to recognize that event contracts aren't just bets, they provide real value through information and risk management.
I also appreciate the academic research behind prediction markets. Studies show they aggregate data better than many other methods, and that transparency helps everyone make better decisions. As a regular citizen, I value the freedom to participate in legal, regulated markets like these. It's not just about making a profit, it's about having a stake in understanding the world around me.
Please consider proportionate regulation that addresses specific risks without shutting down the whole industry. Prediction markets have a lot to offer, and I hope the CFTC will support their growth under a fair framework.
Sincerely,
Crystal Benavidez
