Comment Text:
Dear Chairman and Commissioners,
My name is Dovid Cohen, and I'm an artist and educator based in Connecticut. I'm 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 strongly support their existence under thoughtful, balanced regulation by the CFTC. I believe these markets offer unique value to people like me, and I hope my perspective as a creative professional and teacher can add to this important discussion.
As someone who often juggles unpredictable income from art commissions and teaching gigs, I see prediction markets as a potential tool to manage financial risks tied to events beyond my control. For instance, hedging against policy changes or economic shifts that could affect funding for arts programs or my ability to travel for exhibitions makes a lot of sense to me. I think many individuals and small businesses share this need to protect against uncertainty, and prediction markets can help us do that in a way traditional investments often can't.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, seem far safer than unregulated offshore alternatives. If we over-restrict or ban these markets, I worry activity will just move to less transparent, riskier spaces where users have no protections. The US has a chance to lead in financial innovation here. We shouldn't cede that ground to other countries by being overly cautious. Lets set the standard for how these markets should work.
I understand concerns about manipulation or insider trading, but I believe the answer lies in proportionate, targeted rules, not broad bans. The CFTC already has tools to address bad actors in other markets, and those can be adapted here. Plus, informed trading often improves price discovery, which benefits everyone by making predictions more accurate. This ties into questions 7 and 29 from the ANPR, on balancing innovation with protection and the role of informed traders. I think regulation should focus on specific risks rather than shutting down entire categories of contracts.
I'm not a financial expert, but as an artist, I value tools that let regular people engage with and understand complex events. Prediction markets do that. I urge the CFTC to support their growth with fair rules that protect participants without stifling potential. Please prioritize innovation and access while addressing legitimate risks through focused oversight.
Thank you for considering my input.
Sincerely,
Dovid Cohen