Comment Text:
Dear Chairman and Commissioners,
My name is Jonathan Lozano, and I'm just a regular citizen 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 new to prediction markets, but I've been reading up on them, and I strongly support their existence under fair and sensible regulation. I believe these markets offer unique value to people like me and to society as a whole, and I hope the CFTC will craft rules that allow them to thrive without over-restricting access.
I first got interested in prediction markets because I kept seeing how often polls and pundits get things wrong, especially during elections. I've read about studies showing that prediction markets consistently produce more accurate forecasts by pooling information from lots of different people. That kind of insight isn't just helpful for traders; it's useful for anyone trying to understand what's really going on with public events. As someone who tries to stay informed, I think having access to this data is incredibly valuable, and I want the CFTC to recognize that in its rules.
What also matters to me is the freedom to participate in legal, regulated markets. I'm not a big investor or anything, but I like the idea that everyday folks like me can take part in these markets, not just Wall Street types. If the CFTC bans or overly restricts prediction markets, I worry it will push activity to unregulated offshore platforms where there's no oversight at all. I've read about Kalshi, a regulated platform under CFTC rules, and it seems clear to me that having markets operate here in the US with proper safeguards is far safer than driving people to sketchy overseas sites.
Another concern I have is the idea of classifying event contracts as gaming. I don't see it that way. These contracts let people make informed decisions about real-world events, whether it's an election outcome or some other public issue. That feels more like investing based on research and judgment, not gambling. I think the CFTC should treat them as legitimate financial tools, as they serve a real economic purpose.
Specifically, I'm drawn to Questions 7 and 15 from your ANPR. On Question 7, about balancing innovation and consumer protection, I believe regulated prediction markets strike that balance by fostering transparency while keeping bad actors in check with existing laws. On Question 15, regarding gaming definitions, I urge you to avoid labeling these contracts as gaming, since they aren't about chance but about informed forecasting.
I ask the CFTC to support proportionate regulation of prediction markets. Please don't ban or overly restrict them. Focus on targeted rules to address specific risks while letting regular people like me access these tools for information and participation. Thank you for considering my perspective.
Sincerely,
Jonathan Lozano