Comment Text:
Dear Chairman and Commissioners,
My name is Philip DAgostino, and Im a small business owner from Florida. I run a few businesses here, and Ive come to rely on prediction markets as a tool to stay informed and manage risks that affect my operations. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to voice my strong support for well-regulated prediction markets. I believe they provide unique value to people like me and to society as a whole, and I urge the CFTC to adopt proportionate rules rather than overly restrictive bans.
Every day, I check platforms like Kalshi and Polymarket to get a read on events that could impact my businesses, whether its an upcoming election, a Federal Reserve decision, or even a major weather event in my area. The forecasts on these markets are often more accurate than anything I see from polls or pundits. That information helps me make better decisions, like timing inventory purchases or planning for potential policy changes. Beyond my own use, I see how these markets aggregate information in a way that benefits everyone, from journalists to policymakers, by providing clearer signals about whats likely to happen.
I also use prediction markets to hedge real financial risks. For example, an election outcome can shift tax policies or regulations that hit my bottom line directly. Trading on these markets lets me offset some of that uncertainty. This isnt gambling, as some might claim. It takes research and judgment, much like trading stocks or commodities. Classifying event contracts as gaming undercuts their legitimate economic purpose, and Id ask the CFTC to recognize this distinction when addressing Questions 15-22 on listed activities.
Im not blind to concerns about manipulation or insider trading, but the CFTC already has powerful tools to tackle those issues. Laws already ban federal employees from trading on nonpublic information, and your existing authority over market manipulation covers prediction markets too. Banning or over-restricting these markets, as discussed in Questions 7-14 on public interest, would just push activity to unregulated offshore platforms where theres no oversight at all. Id much rather trade on a regulated platform like Kalshi, under CFTC supervision, than take my chances somewhere less safe. Regulation, not prohibition, is the answer to consumer protection.
On a broader level, responding to Questions 33-40 on classification and costs, I believe the US should be a leader in financial innovation. If we over-regulate or ban prediction markets, were handing that leadership to other countries. Informed trading, as noted in Questions 29-32, actually improves price discovery and makes markets more accurate for everyone. Lets not punish the many for the potential misdeeds of a few.
I urge the CFTC to support proportionate, targeted regulation of prediction markets. Focus on specific risks with existing tools rather than broad categorical bans. This approach keeps markets safe, accessible, and valuable to small business owners like me and to the public at large.
Thank you for considering my perspective.
Sincerely,
Philip DAgostino