Comment Text:
Dear Chairman and Commissioners,
My name is Roman Mozharov, and I'm a trader and investor based in California. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi and Polymarket, I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to society and to people like me who rely on accurate information to make decisions.
I've found prediction markets to be an incredible tool for forecasting events, especially elections and other public outcomes. The prices on these platforms often cut through the noise of polls and pundits, giving a clearer picture of what's likely to happen. This isn't just useful for traders; it helps everyone, from journalists to policymakers, make sense of complex issues. I also value how these markets democratize access to information. They let regular people like me participate, not just big institutions, and that broader input makes the forecasts sharper. For me, trading on these platforms isn't gambling. It takes research and judgment, much like trading stocks or commodities. Classifying event contracts as "gaming" ignores their legitimate economic purpose, whether it's price discovery or hedging risks tied to real-world events.
I'm also a firm believer that regulation is the way to go, not restriction. I've seen unregulated offshore platforms out there, and they're far riskier for consumers like me. A regulated market under the CFTC's oversight, with transparency and data sharing, is safer and builds trust. I appreciate that the CFTC is looking at consumer protection, as raised in Questions 7 through 14 on public interest. I urge you to balance innovation with those protections, not to over-restrict or ban these markets. On the topic of gaming, addressed in Questions 15 to 22, I want to stress again that event contracts aren't games of chance. They reflect informed bets on real outcomes, often backed by academic research showing their forecasting power. I'd encourage the CFTC to lean on that research when defining what these markets are.
I understand concerns about manipulation or insider trading, as discussed in Questions 29 to 32. But those issues are already illegal under existing laws, and the CFTC has tools to enforce them. Shutting down or overly restricting prediction markets to stop a few bad actors would punish the rest of us who use them responsibly. It's like closing a highway because some people speed. Use the tools you have; don't take away the road.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Let them grow under clear, fair rules that protect consumers without stifling their benefits for forecasting and decision-making. Thank you for considering my perspective.
Sincerely,
Roman Mozharov
