Comment Text:
Dear Chairman and Commissioners,
My name is David Jocson, and I'm a trader and investor from Oregon. I'm writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide unique opportunities and benefits for individuals like me, as well as for society at large.
Prediction markets are a critical tool for me to access financial markets and make a living, especially during times when traditional markets are closed. From Friday evening to Sunday evening, and often during holidays, the stock market, futures, forex, and options exchanges are unavailable. Thats over 100 trading days a year Id lose without prediction markets. These markets give me, and countless other U.S. citizens, the chance to use our capital and skills to profit when others around the world cant. The economic advantage of this for the U.S. is massive. Its like a business operating 100 extra days compared to a competitor. Beyond my personal gain, the data from these markets offers immense value for public policy, financial analysis, academic research, and technological innovation.
I believe prediction markets are not gambling. They require research, analysis, and real-world judgment, much like trading stocks or commodities. They also serve legitimate economic purposes, like hedging risks. For instance, I can hedge against election outcomes or policy changes that might impact my taxes or investments. Plus, the forecasting accuracy of these markets often outshines polls or pundits, providing better information for public decision-making and price discovery. This isnt just good for traders; it benefits everyone.
Addressing some of your specific questions, like those in Topic B on public interest (Questions 7-14), I urge you to prioritize innovation and U.S. competitiveness. Prediction markets are the next layer of financial innovation in our advanced economy, much like derivatives, which thrive here but not in less liquid markets like much of Europe. By fostering these markets, you empower everyday Americans, especially those of us below median wealth, to improve our financial standing using personal experience and self-directed learning. This trust in citizens to manage their own capital sets the U.S. economy apart. As for Topic C on listed activities (Questions 15-22), event contracts should not be classified as gaming. They have real economic utility, unlike pure chance-based activities.
I understand concerns about insider trading or manipulation, as raised in Topic E (Questions 29-32). But banning or over-restricting these markets isnt the answer. Those behaviors are already illegal, and the CFTC has tools to enforce against bad actors. Shutting down prediction markets would push activity to unregulated offshore platforms, which are far less safe than regulated venues like Kalshi. Informed trading, meanwhile, improves price discovery for everyone. Proportionate, targeted regulation is the way forward, not broad bans.
I ask that the CFTC support well-regulated prediction markets to ensure the U.S. leads in financial innovation while protecting participants with sensible rules. Dont let over-regulation stifle this opportunity for everyday Americans like me.
Sincerely,
David Jocson
