Comment Text:
Dear Chairman and Commissioners,
My name is Mike Cunningham, and I'm a software engineer based in Texas. I'm writing to express my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who works in tech, I value innovation and data-driven solutions, and I believe prediction markets are a powerful tool for forecasting and economic participation that the CFTC should encourage with balanced regulation.
I've used prediction markets a few times myself, mostly to gauge outcomes of elections and major public events. What strikes me is how often these markets get it right compared to polls or pundits. They aggregate information in a way that's just more accurate, and that benefits everyone, not just traders like me. It's not about gambling; it takes real research and judgment to participate, much like any other investment. Classifying event contracts as "gaming" feels off base to me. They serve legitimate purposes, like price discovery and hedging, and shouldn't be lumped in with betting.
I also believe in the freedom to make my own choices. If we're truly the land of the free, the government shouldn't be in the business of protecting us from our own decisions. Let us participate in legal, regulated markets. I'm concerned that banning or over-restricting prediction markets will just push activity to offshore platforms with no oversight. I'd much rather see the CFTC regulate these markets here in the US, keeping them safe and transparent. On top of that, the US should be leading in financial innovation. We can't afford to cede ground to other countries on something this cutting-edge.
I want to touch on a couple of your specific questions from the ANPR. Regarding Question 7 under Public Interest, I think prediction markets absolutely serve the public good by providing better forecasts than traditional methods. And on Question 29 under Inside Information, I believe informed trading actually improves price discovery. It makes the market smarter, and that helps everyone who relies on the data, from regular folks like me to policymakers.
As a tech professional, I'm also aware of the academic research backing prediction markets. Studies show they improve information aggregation, and that transparency is valuable for society. Let's not throw that away with heavy-handed rules.
I urge the CFTC to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Create a framework that addresses risks like manipulation or insider trading with targeted rules, using the tools you already have. Keep the US at the forefront of innovation, and let people like me participate in a fair, regulated system.
Thank you for considering my perspective.
Sincerely,
Mike Cunningham
