Comment Text:
Dear Chairman and Commissioners,
My name is John Moilinga, and I'm a student from New Jersey writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm new to prediction markets, but I've been studying them as part of my academic work, and I strongly support their development under sensible, well-thought-out regulation by the CFTC.
As a student, I see prediction markets as a powerful tool for understanding the world. They aggregate information in ways that polls and pundits often can't match, especially for elections and major public events. That kind of accurate forecasting isn't just interesting to me academically; it's valuable for society. Better information helps everyone make smarter decisions, whether it's a voter, a journalist, or a policymaker. I also believe these markets give regular people like me a chance to participate in a financial system that often feels closed off. Banning or over-restricting them would just push activity to unregulated offshore platforms, which are far riskier for consumers than a regulated market like Kalshi operating under CFTC oversight.
I'm also drawn to how prediction markets let individuals and businesses hedge real financial risks. For instance, a small business owner could use these markets to protect against policy changes or economic shifts tied to election outcomes. This isn't gambling. It's a legitimate economic tool, and classifying event contracts as "gaming" misses their purpose. They serve a real need for price discovery and risk management, much like other derivatives the CFTC already regulates. On top of that, informed trading in these markets actually improves the accuracy of the prices, benefiting everyone, not just the traders.
I want to address a few specific questions from the ANPR. On Questions 7-14 about public interest, I think the CFTC should prioritize innovation while protecting consumers by keeping markets onshore and regulated, not by banning them. For Questions 15-22 on listed activities, event contracts shouldn't be lumped in with gaming; they have clear economic value. And on Questions 29-32 about inside information, I believe the CFTC already has strong tools to tackle manipulation and insider trading. Use those instead of broad restrictions that hurt honest participants. Finally, the US should lead in financial innovation. If we over-regulate or ban these markets, we risk ceding ground to other countries, and that's a missed opportunity.
I understand concerns about manipulation or unfair play, but shutting down entire markets to stop a few bad actors isn't the answer. Focus on enforcing existing laws and crafting targeted rules. I urge the CFTC to support proportionate regulation of prediction markets, ensuring they remain legal, accessible, and safe for participants like me who see their value both academically and practically.
Thank you for considering my input.
Sincerely,
John Moilinga
