Comment Text:
Dear Chairman and Commissioners,
My name is Shubham Dabra, and Im a software engineer based in Washington state. Im writing to share my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone in the tech field, Ive always been fascinated by how data and systems can solve real-world problems, and Ive used prediction markets a few times myself to test their insights. I believe they offer unique value to society and deserve thoughtful, proportionate regulation rather than overly restrictive rules.
Ive seen firsthand how prediction markets can cut through noise and provide clearer forecasts than polls or pundits. For instance, during the last election cycle, I checked platforms like Kalshi to gauge outcomes that affected tech policies, and their predictions were often sharper than what I read in the news. This isnt just helpful for me; its a public good when better information is available to everyone. Beyond forecasting, these markets also let individuals and businesses hedge real risks. As someone who works in tech, I can imagine startups or developers using event contracts to offset uncertainties around regulatory changes or funding environments. Its practical, not speculative.
I also worry that if the U.S. doesnt embrace this space, we risk losing ground to other countries. Tech innovation is a race, and prediction markets are a frontier where the U.S. should lead, not follow. Banning or over-regulating them could push activity to offshore platforms with no oversight, which helps no one. On a related note, I strongly believe event contracts arent gambling. They serve economic purposes like price discovery and risk management, much like other financial tools Im familiar with as an engineer analyzing data trends. Academic research backs this up too. Studies by economists like Hanson and Wolfers show how these markets aggregate information efficiently. We should lean on that data, not dismiss it.
Addressing some of your specific questions, like those in Topic B on public interest (Questions 7-14), I think the CFTC should prioritize balancing innovation with consumer protection by focusing on transparency and existing anti-manipulation tools rather than broad restrictions. And on Topic C about listed activities (Questions 15-22), I urge you not to classify these contracts as gaming. Theyre grounded in research and real-world utility, not chance.
I know there are concerns about insider trading or manipulation, and those are valid. But the CFTC already has laws and powers to tackle bad actors. Punishing everyone by limiting these markets isnt the answer. Instead, I ask that you craft rules that support prediction markets while targeting specific risks with precision.
Thank you for considering my input. I hope youll regulate prediction markets in a way that preserves their benefits and keeps the U.S. at the forefront of financial innovation.
Sincerely,
Shubham Dabra
