Comment Text:
Dear Chairman and Commissioners,
My name is Raphael Gurevich, and I'm just an everyday citizen from New York writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I strongly support their continued operation under fair and proportionate regulation. I believe they provide unique value to society, especially when it comes to better information for public decision-making and accurate forecasting of events like elections.
I've always been frustrated by how often polls and pundits get things wrong, whether it's an election outcome or some big public event. A few years back, I started looking into prediction markets out of curiosity, and I was amazed at how often their prices reflected what actually happened, way more than any news outlet or survey. Ive placed a few small trades myself, not to make a fortune, but to follow along and see how the crowds wisdom plays out. That kind of real-time, aggregated insight isn't something you can get anywhere else. It's not just useful for traders like me, but for anyone who wants a clearer picture of what's likely to happen, whether that's journalists, policymakers, or just regular people trying to make sense of the world.
I also think that when informed traders participate, it makes the market better for everyone. Their knowledge helps the prices reflect reality more accurately, which is a public good. Yes, theres a concern about insider trading or manipulation, but I dont think the answer is to shut down these markets or over-restrict them. Those issues are already illegal, and the CFTC has the tools to enforce the rules. Banning or heavily limiting prediction markets because of a few bad actors feels like punishing everyone for something most of us aren't doing. It's like closing the stock market over insider trading scandals. Focus on enforcement, not prohibition.
Specifically, regarding Questions 7 and 11 in the ANPR about public interest and price discovery, I believe prediction markets serve a critical role in providing accurate forecasts that benefit society at large. They aren't gambling; theyre a tool for understanding complex events. And on Question 29 about inside information, I think informed trading often improves price accuracy, as long as its not based on illegal nonpublic information. The CFTC should target those specific abuses, not the markets themselves.
I urge you to support well-regulated prediction markets that allow regular people like me to participate and access this unique information. Please dont impose broad bans or overly restrictive rules that would push this activity offshore or underground. Proportionate regulation is the way to go.
Thank you for considering my perspective.
Sincerely,
Raphael Gurevich
