Comment Text:
Dear Chairman and Commissioners,
My name is Jacob Rich, and I'm a student from Arizona. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets, and I want to share my perspective as someone who has used these platforms a few times and believes they offer real value when handled responsibly.
As a student, I've dabbled in prediction markets to get a better sense of real-world events, like election outcomes or economic indicators. It's not just about making a few bucks; it's about accessing information that I can't find in news articles or polls. These markets often seem to cut through the noise and give a clearer picture of what's likely to happen. I think that's valuable for everyone, not just traders. But what worries me is the idea of banning or over-restricting these markets. If that happens, people like me won't just stop participating. We'll get pushed to unregulated offshore platforms that don't have any oversight. I've seen those sites, and they feel like a gamble in a bad way, with no protections if something goes wrong. Regulated markets, like Kalshi operating under CFTC rules, are far safer. They have transparency and accountability that offshore alternatives lack.
I also want to push back on the idea that event contracts are just "gaming." That's not how I see it at all. When I trade on a prediction market, I'm doing research, weighing probabilities, and making informed decisions about real-world events. That feels a lot closer to investing than to rolling dice at a casino. These markets serve a real purpose, whether it's helping people hedge against uncertainty or just aggregating information for better forecasts. Classifying them as gaming would be a mistake and could unfairly limit access for regular folks like me who want to participate in a legal, regulated space.
Looking at some of the specific questions in the ANPR, I think Question 8 about balancing innovation and consumer protection hits the nail on the head. Regulation is the answer, not prohibition. Keep prediction markets under CFTC oversight to protect users while still allowing innovation. And on Question 15, about defining gaming versus legitimate markets, I urge you to recognize the economic value of event contracts and not lump them in with gambling.
I believe in the freedom to participate in legal, regulated markets, and I think the CFTC can strike the right balance here. Please support proportionate regulation of prediction markets instead of broad bans or overly tight restrictions that would drive activity to unsafe, offshore platforms. Thanks for considering my input.
Sincerely,
Jacob Rich
