Comment Text:
Dear Chairman and Commissioners,
My name is Andrew Spiegel, and I'm an everyday citizen from New York writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Im not a trader myself, but I follow prediction markets closely and believe they serve an important purpose. I work with Apex, a business that helps clients launch investing capabilities, and many of them are explicitly asking for access to event contracts. Im writing to urge the CFTC to support well-regulated prediction markets with proportionate rules rather than broad restrictions.
I see prediction markets as a powerful tool for everyday people and businesses to hedge real risks. Whether its a small business owner worried about policy changes after an election or an individual trying to offset uncertainties tied to economic data releases, these markets provide a way to manage exposure that isnt available elsewhere. Beyond hedging, the information these markets produce is often more accurate than polls or pundits. That kind of price discovery helps everyone, not just traders, by offering clearer signals for public decision-making. Ive seen firsthand how clients at Apex are hungry for this kind of data to inform their strategies.
Im also concerned about U.S. competitiveness. If we over-regulate or ban prediction markets, we risk pushing innovation offshore to unregulated platforms where consumer protections are weak or nonexistent. The U.S. should be leading in financial innovation, not ceding ground to other countries. Regulated markets, like those overseen by the CFTC, are a safer and more transparent option. I believe in consumer protection, but it should come through smart oversight, not by shutting down legal, regulated spaces where people can participate freely.
On the specific questions in the ANPR, Id like to address a few from Topic B on Public Interest, like Question 7 about balancing innovation and protection. I think the CFTC can strike that balance by focusing on targeted rules for specific risks, such as manipulation, rather than broad bans. Question 11, on price discovery, is also key. Academic research, which I follow closely, consistently shows prediction markets aggregate information efficiently, and that benefits the public. We should encourage data transparency in these markets to maximize that value.
I understand there are concerns about insider trading or manipulation, but those issues are already illegal under existing laws. The CFTC has the tools to enforce against bad actors without punishing everyone by restricting access. Lets not throw out a useful market because of a few potential risks.
I respectfully ask the CFTC to regulate prediction markets in a proportionate way. Focus on specific problems with targeted solutions, and allow individuals and businesses to participate in legal, regulated environments. Thank you for considering my perspective.
Sincerely,
Andrew Spiegel
