Comment Text:
Dear Chairman and Commissioners,
My name is Almas Mohammadi, and I'm a student from Florida 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, and I believe they have real value for society. I'm asking you to support fair and proportionate regulation of these markets rather than overly restrictive rules or outright bans.
As a student, I'm always looking for reliable information to understand the world, whether it's for a research paper or just to make sense of current events. Prediction markets have stood out to me because they often produce forecasts that are more accurate than polls or pundits. I've seen this firsthand when I checked platforms like Kalshi during the last election cycle. The market prices gave a clearer picture of what might happen compared to the endless back-and-forth on TV or social media. This isn't just useful for me; it's valuable for anyone who needs solid data, from journalists to policymakers. I think that's a public good worth protecting.
I also care a lot about consumer protection. I know there are risks with prediction markets, like potential manipulation or uninformed people losing money. But banning or over-restricting them isn't the answer. If you push these markets underground or to offshore platforms, people like me lose the safeguards that come with regulated U.S. markets. I've read about unregulated sites operating outside CFTC oversight, and they seem far riskier with no accountability. Regulation can address these concerns without killing innovation. Keep these markets in the U.S., under your watch, with clear rules to protect users.
Regarding some of the specific questions in the ANPR, I want to touch on Question 7 under Public Interest. You asked how to balance innovation with consumer protection. I think the CFTC can do this by setting standards for transparency and anti-manipulation, much like you do for other financial markets, while still allowing prediction markets to grow. Also, on Question 15 under Listed Activities, I don't think these markets should be labeled as gaming. Theyre about aggregating real-world information, not luck or chance, and that serves a purpose beyond entertainment.
I understand there are legitimate worries about insider trading or market abuse. But those issues are already illegal under existing laws, and the CFTC has tools to enforce them. Shutting down prediction markets to stop a few bad actors would punish everyone else who uses them responsibly. Instead, please focus on targeted rules to address specific risks.
I urge you to support well-regulated prediction markets that allow ordinary people like me to access valuable information while ensuring safety through oversight. Thank you for considering my perspective.
Sincerely,
Almas Mohammadi
