Comment Text:
Dear Chairman and Commissioners,
My name is Geoffrey Griffith, and I'm a software engineer from Ohio. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to your 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, I've seen firsthand the value these markets provide, and I urge the CFTC to craft rules that protect consumers without stifling innovation or access.
Prediction markets aren't just a hobby for me; they're a tool. As a tech professional, I deal with data and systems every day, and I can tell you these markets produce forecasts that consistently beat polls and pundits. I've relied on them for insights into election outcomes and other public events, and their accuracy helps me make better personal and financial decisions. Beyond that, they offer a way to hedge real risks. For example, I've used event contracts to offset potential impacts of policy changes that could affect my freelance tech projects or personal investments. This isn't gambling. It takes research and judgment, much like trading stocks, and classifying these contracts as "gaming" ignores their legitimate economic purpose.
I'm also concerned about over-restriction or outright bans. If the CFTC clamps down too hard, it won't stop prediction markets; it will just push activity to unregulated offshore platforms where there's less oversight and more risk. I'd much rather trade on a regulated U.S. market like Kalshi, where I know the CFTC is watching for manipulation. And speaking of manipulation, I believe informed trading actually helps. When people like me bring valuable, publicly available information into the market, often stuff that's ignored due to groupthink, it improves price discovery for everyone. This ties directly to your questions in Topic E, like Question 29 on whether informed traders aid price discovery. I think they absolutely do, and the CFTC should encourage that while enforcing existing laws against insider trading.
I also want to address Topic B, specifically Question 7 on balancing innovation and consumer protection. Prediction markets give regular people like me access to information and risk management tools that big institutions have always had. Shutting that down would be unfair and counterproductive. The public benefits when we all have better data for decision-making, whether it's about elections or economic trends. The answer isn't to ban these markets over fears of bad actors; it's to use the tools you already have to police manipulation and fraud.
I ask the CFTC to support well-regulated prediction markets that allow everyday citizens to participate. Don't over-restrict or ban event contracts. Craft rules that address specific risks while preserving the benefits these markets bring to people like me and to society as a whole. Thank you for considering my input.
Sincerely,
Geoffrey Griffith
