Comment Text:
Dear Chairman and Commissioners,
My name is Manny Ceja, and Im a policy and government professional based in Texas. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive used prediction markets a few times myself, and I strongly support their continued operation under fair, proportionate regulation. I believe these markets provide unique value to society, especially for those of us who care about accurate forecasting and better public decision-making.
In my work, I often see how hard it is to get reliable information on elections and major public events. Prediction markets have consistently outperformed polls and pundits in forecasting outcomes, and thats not just useful for traders like me, its valuable for everyone. The aggregated wisdom in these market prices helps inform public discourse and even policy decisions. Ive personally relied on these platforms to gauge sentiment on key issues, and Ive found the insights far sharper than what traditional media or surveys offer.
I also want to stress that event contracts arent gambling. They serve real economic purposes, like price discovery and hedging against uncertainty. Classifying them as gaming would be a mistake, as it ignores the research and judgment that goes into trading, much like in traditional financial markets. This isnt a game of chance, its a tool for understanding the world. On this point, Id direct your attention to Questions 15-22 in the ANPR about defining gaming versus legitimate markets. I urge the CFTC to recognize the distinct economic utility of event contracts and avoid overly broad or restrictive categorizations.
Another concern I have is the risk of over-restriction or outright bans pushing activity offshore to unregulated platforms. If we stifle these markets here, we lose oversight and drive participants to less safe venues. The U.S. should be leading in financial innovation, not ceding ground to other countries. Regulated markets, like those on CFTC-registered exchanges, are the better path. I think Questions 7-14 on balancing innovation and consumer protection are crucial here, and I encourage rules that foster growth while addressing specific risks.
Finally, on the topic of informed trading, I believe it improves price discovery and benefits all participants. Banning or limiting markets because of insider trading fears ignores the fact that such behavior is already illegal. The CFTC has tools to tackle manipulation and should use them rather than punishing everyone. This ties to Questions 29-32 on inside information, where Id argue that informed trading often makes markets more accurate, not less.
I appreciate the CFTC seeking public input on this. Prediction markets matter to me as a Texan and a policy professional, and I believe they matter to our countrys future. Please support proportionate regulation that allows these markets to thrive while addressing specific concerns, rather than imposing broad restrictions or bans.
Sincerely,
Manny Ceja
