Comment Text:
Dear Chairman and Commissioners,
My name is Dylan Giss, and I'm a student from Georgia writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm passionate about innovation, especially when it doesn't harm anyone, and I believe prediction markets offer real value to society. I've used these platforms a few times myself, and I want to share why I support well-regulated prediction markets rather than heavy restrictions or bans.
As a student, I see the incredible value in the accurate forecasting that prediction markets provide. They've consistently outperformed polls and pundits when it comes to predicting election outcomes and other public events. This isn't just useful for traders; it's better information for everyone, from journalists to regular citizens like me trying to understand what's happening. Plus, these markets let individuals and businesses hedge real financial risks. For example, someone could use them to offset uncertainties around policy changes that impact personal finances or small businesses. This isn't gambling. It's a tool for managing risk, much like trading stocks or commodities, and I don't think event contracts should be classified as gaming when they serve clear economic purposes.
I'm also worried about what happens if we over-restrict these markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore sites. If prediction markets are banned or pushed out of many states due to category changes, people will turn to sketchy alternatives that lack any oversight. I've signed up for these platforms myself, and as an adult, I understand the risks. Why punish everyone for the actions of a few when regulated markets already require KYC processes to prevent fraud?
On the topic of insider trading, I don't think it should be used as a reason to restrict prediction markets. It's already a problem in other sectors, like the stock market, where even politicians have been known to use classified info for profit. Solutions exist for that, and the CFTC already has robust tools to tackle manipulation and insider trading. Let's adapt those instead of broad bans. I also believe the US should be a leader in financial innovation. We shouldn't cede this space to other countries by over-regulating.
Id like to address a few specific questions from the ANPR. On Question 7, regarding public interest, I think prediction markets clearly serve the public by improving price discovery and access to information. On Question 15, about defining gaming, I argue these contracts aren't gambling since they involve research and judgment, just like other investments. And on Question 33, about classification, I urge the CFTC to avoid treating event contracts as something separate from legitimate derivatives.
In closing, I ask you to support proportionate, targeted regulation of prediction markets. Don't ban or overly restrict them. Focus on specific risks with the tools you already have. Let's keep innovation alive and accessible to everyday people like me.
Sincerely,
Dylan Giss
