Comment Text:
Dear Chairman and Commissioners,
My name is Michael Bogart, and I'm a trader and investor based in New Jersey. I've been involved in various markets for years, and I've used prediction markets a few times to get a sense of where things might be headed on certain events. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets and want to share why I think they deserve a fair shot under proportionate rules.
As someone who spends a lot of time analyzing data and making informed bets in traditional markets, I see prediction markets as a unique tool. They consistently produce forecasts that are more accurate than polls or pundits. I've seen this firsthand when I checked platforms for election outcomes or economic indicators, and the market's "crowd wisdom" often beats the talking heads on TV. This isn't just useful for traders like me. It helps everyone, from businesses planning for policy changes to regular folks trying to understand what's likely to happen. Shutting down or over-restricting these markets would mean losing that valuable insight.
I also care deeply about the freedom to participate in legal, regulated markets. Prediction markets aren't some shady backroom deal. Platforms like Kalshi, which operate under CFTC oversight, provide a safe and transparent space for people like me to trade. That's a far cry from unregulated offshore platforms where there's no accountability. If you clamp down too hard on legitimate markets, you're just pushing activity to those riskier, less safe venues. I've traded enough to know that regulation done right keeps everyone honest without killing innovation.
To touch on some of your specific questions in the ANPR, I think Question 7 under Public Interest hits the nail on the head. How do we balance innovation with consumer protection? My view is that regulated markets already offer that balance. They let people participate while having guardrails in place. And on Question 23 under Procedural Aspects, I'd argue public interest determinations should happen early but not be so restrictive that they block entire categories of contracts before they even get started.
I get the concerns about manipulation or insider trading. Those are real issues in any market, not just prediction markets. But the CFTC already has tools to tackle fraud and abuse. Use those instead of broad bans that punish law-abiding participants like me. I urge you to craft rules that protect consumers without stifling the benefits these markets bring. Lets keep prediction markets legal, regulated, and accessible to everyday traders.
Thank you for considering my input.
Sincerely,
Michael Bogart
