Comment Text:
Dear Chairman and Commissioners,
My name is George Clark, and Im a lawyer based in California. Im writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi and Polymarket, Ive seen firsthand the value these markets provide, both to individuals like me and to society at large. I believe the CFTC has a unique opportunity to foster innovation while protecting consumers, and I urge you to avoid overly restrictive rules or outright bans.
Prediction markets arent just a niche interest for me; theyre a tool that consistently delivers information I cant find elsewhere. Ive relied on them to gauge election outcomes and other public events, and time and again, their forecasts have proven more accurate than polls or pundits. This isnt speculation or gambling. Its a process grounded in research and judgment, much like trading stocks or commodities. As a lawyer, I see event contracts as serving real economic purposes, like hedging risks tied to political or economic uncertainty. For instance, Ive used these markets to offset potential impacts of policy changes on my small legal practice. This hedging utility isnt hypothetical; its practical and valuable.
I also want to emphasize the importance of regulated markets over unregulated alternatives. Platforms like Kalshi, operating under CFTC oversight as a designated contract market, provide transparency and accountability that offshore platforms like Polymarket cant match. If the CFTC imposes bans or excessive restrictions, activity will simply move to these less safe venues. Thats not a solution; its a step backward. The United States should lead in financial innovation, setting global standards rather than ceding ground to other jurisdictions.
Addressing some of your specific questions in the ANPR, I believe informed trading enhances price discovery and benefits all participants, as raised in Questions 29-32 on inside information. Banning markets to prevent potential insider trading punishes legitimate users while ignoring existing laws that already prohibit such behavior. On Questions 7-14 regarding public interest, I urge you to consider the extensive academic research supporting prediction markets as tools for accurate forecasting and data transparency. These markets democratize access to critical insights, and thats a public good worth protecting.
Im not blind to the risks of manipulation or misuse, but the CFTC already has robust tools to address those issues in other derivatives markets. Adapt those safeguards here. Dont let a few bad actors justify restricting an entire industry. My ask is simple: craft rules that allow legal, regulated prediction markets to thrive while targeting specific harms with precision. Lets keep this innovation alive in the U.S., under proper oversight, for the benefit of individuals, businesses, and the public.
Thank you for considering my views.
Sincerely,
George Clark
