Comment Text:
Dear Chairman and Commissioners,
My name is Bret Lewis, and I'm a lawyer based in California. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I have deep reservations about these products, I feel compelled to offer my perspective as someone who has dabbled in them and recognizes the broader implications of outright bans versus regulation. I've used prediction markets a few times, putting down about $100, and to be frank, I see them as gambling, pure and simple. I believe they can be corrupting and pose risks to the public. I see no practical need for the United States to maintain leadership in this innovation, which is why Im advocating for a complete ban not for strict, targeted regulation.
As a legal professional, I often advise clients on managing financial risks, including hedging against uncertainties like regulatory changes or economic shifts. Prediction markets could, in theory, serve as tools for hedging personal or business risks, such as anticipating policy outcomes that impact taxes or operational costs. I've seen firsthand how uncertainty can cripple planning. However, these products are obscene, promote illegality, corruption, and distrust in the world and personal growth. I remain skeptical of these markets' broader value. My own brief experience with these platforms, though, left me uneasy; it felt more like a game of chance than a serious financial instrument.
While I believe the U.S. must lead in financial innovation rather than cede ground to other countries, I do not believe the CFTCs existing tools to combat insider trading and manipulation can be adapted here. We would need to reinvent the wheel; it would be too difficult to implement and the spectre of unfairness will still permeate every area.
My personal view is that these markets are akin to gambling and should ideally be banned. Lets keep the U.S. at the forefront of financial markets, but with guardrails that protect the public from the corrupting potential like Kalshi Ive seen in these platforms before all our children our addicted compulsive gamblers.
Sincerely,
Bret Lewis
