Comment Text:
Dear Chairman and Commissioners,
My name is Alexander Guerrero, and I'm a student from Illinois. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I strongly support their regulation in a balanced way that allows them to thrive while addressing real concerns. I believe these markets offer unique value to people like me and to society as a whole.
As a student, Im always looking for reliable information to understand the world, especially during big events like elections. Prediction markets have consistently provided forecasts that are more accurate than polls or pundits. Ive seen this firsthand when checking platforms like Kalshi for election odds; their numbers often cut through the noise of opinion pieces and give a clearer picture of what might happen. This isnt just useful for me. Its valuable for anyone trying to make sense of public events, from journalists to everyday citizens.
I also see prediction markets as a tool for managing personal financial risks. For example, if Im planning my budget or thinking about a future job tied to economic policy, knowing the likelihood of a certain election outcome or policy change helps me prepare. This isnt gambling. Its a practical way to hedge against uncertainty, much like people use other financial tools. Labeling event contracts as gaming feels off to me when they serve real economic purposes like this.
Im glad the CFTC is considering regulation, but I worry about over-restricting these markets. Regulated platforms like Kalshi are far safer than unregulated offshore sites. If we push too hard with bans or heavy rules, people will just turn to those less secure options, and that helps no one. Plus, the US has a chance to lead in financial innovation here. We shouldnt let other countries take the lead on something that could shape how we understand and manage risk in the future.
Looking at some of the specific questions in the ANPR, I want to address a couple from the Public Interest section. For Question 7, on balancing innovation and consumer protection, I think the focus should be on clear rules for transparency and anti-manipulation, not broad prohibitions. And for Question 14, comparing these markets to insurance, Id argue theyre closer to other financial instruments since they help with price discovery and hedging, not just risk transfer.
I urge you to support proportionate regulation of prediction markets. Dont ban or overly restrict them. Theyre a powerful tool for forecasting and managing uncertainty, and with the right oversight, they can benefit everyone while minimizing risks. Thank you for considering my perspective.
Sincerely,
Alexander Guerrero