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Comment for Proposed Rule 91 FR 12516

  • From: Marchetta Silvernail
    Organization(s):

    Comment No: 117286
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Marchetta Silvernail, and I'm a student from California writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm relatively new to prediction markets, but I've been learning about them in my academic studies, and I strongly support their potential when properly regulated by the CFTC. I believe these markets can benefit society in meaningful ways, and I want to offer my perspective as a young person concerned about information quality and innovation.


    One reason I support prediction markets is their ability to produce better forecasts than traditional polls or pundit opinions. In my studies, I've read about how these markets aggregate information from many participants to predict outcomes, often with surprising accuracy. This isn't just useful for traders; its valuable for the public and decision-makers who need reliable data to navigate complex issues. As a student, I see how much bad information circulates online. Prediction markets could cut through that noise and give us clearer signals on important events.


    I also worry about the US falling behind in financial innovation. If we over-restrict or ban these markets, we risk pushing activity to unregulated offshore platforms where theres no consumer protection. I've looked into platforms like Kalshi, which operate under CFTC oversight, and its obvious to me that regulated markets are far safer for participants. A heavy-handed approach would just drive people to less transparent venues, which helps no one. We should be leading the way on this technology, not ceding ground to other countries.


    On the topic of classification, I dont think event contracts should be labeled as gaming. From what Ive learned, they serve real economic purposes like price discovery and risk management. Treating them as gambling ignores their value and could stifle a tool that helps people make informed choices. Im glad the CFTC is asking for input on this in questions 15 through 22 under the Listed Activities section. My view is that these contracts are more like investments based on research and judgment, not mere bets.


    Of course, I understand there are risks like manipulation or insider trading, and I support smart regulation to address them. Questions 7 through 14 on balancing innovation with consumer protection resonate with me. We need rules that protect users without killing off a promising tool. The CFTC already has authority to tackle bad actors, so lets use those tools rather than broad bans.


    I urge you to support proportionate regulation of prediction markets. Dont let over-restriction push this innovation offshore or out of reach for regular people like me who see its potential. Thank you for considering my input.


    Sincerely,

    Marchetta Silvernail

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