Comment Text:
Dear Chairman and Commissioners,
My name is Julia Berck, and I'm a trader and investor based in California. I'm writing to express my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've used prediction markets a few times myself, and I believe they offer unique value both to individuals like me and to society at large. I appreciate the CFTC seeking public input on how to approach this growing field.
As someone who spends a lot of time analyzing markets, I find prediction markets to be a powerful tool for accessing information thats hard to find elsewhere. The prices often reflect a clearer picture of likely outcomes than polls or expert opinions. I've seen firsthand how these platforms aggregate data in a way that feels almost crowdsourced, and I think thats a public good. Academic research backs this up, with studies by economists like Robin Hanson and Justin Wolfers showing how prediction markets improve forecasting accuracy. Id urge the CFTC to consider this body of evidence when shaping rules, especially in response to Questions 7 and 8 around public interest and price discovery.
What really concerns me is the risk of pushing activity to unregulated offshore platforms if the CFTC over-restricts or bans certain event contracts. I've traded on regulated markets like Kalshi, and the transparency and oversight there make me feel much safer as a participant. If those options disappear, people wont just stop trading. Theyll go to less safe, unregulated sites where theres no accountability. I think the CFTC should prioritize keeping activity within regulated environments, as touched on in Questions 23 and 24 about procedural determinations. Regulation should protect users, not drive them away.
I understand there are concerns about manipulation or insider trading. Those are valid worries. But the CFTC already has tools to address fraud and abuse in other markets, and those can apply here too. Banning broad categories of contracts to stop a few bad actors feels like overkill. It punishes regular traders like me who are just trying to make informed decisions. I hope the CFTC focuses on targeted rules to handle specific risks, as raised in Questions 29 and 30 about inside information.
Prediction markets arent gambling, in my view. They take research and judgment, much like trading stocks or commodities. Ive used them to think through economic or political events that could impact my investments, and thats a legitimate use. Im asking the CFTC to support proportionate regulation that allows innovation while addressing real risks. Dont let heavy-handed restrictions stifle a tool thats useful to so many.
Thank you for considering my perspective.
Sincerely,
Julia Berck
