Comment Text:
Dear Chairman and Commissioners,
My name is James Tsan, and I'm a software engineer from California. I'm writing to express my support for the proportionate regulation of prediction markets as outlined in the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who works in tech, I value innovation and data-driven tools, and I've used prediction markets a few times myself. I believe they offer unique benefits for accurate forecasting and personal financial planning, and I urge the CFTC to support their growth under a fair regulatory framework.
Prediction markets have been incredibly useful to me for getting a clearer picture of public events like elections. The aggregated data from these platforms often cuts through the noise of polls and media spin, giving me insights I can't find elsewhere. Beyond that, they let regular people like me participate in a legal, regulated space to express our views on future outcomes. I also see real value in using these markets to hedge personal or business risks. For example, as someone in tech, I'm often exposed to economic shifts tied to policy changes or interest rate decisions. Being able to hedge against those uncertainties through event contracts would be a practical tool for managing my finances.
I want to address a couple of specific concerns raised in the ANPR, particularly around public interest and core principles (Questions 1-6 and 7-14). I understand the CFTC's worry about manipulation or insider trading, but I strongly believe the agency already has robust tools to tackle these issues. The same anti-manipulation and insider trading rules that apply to other derivatives can work here. There's no need for overly broad restrictions when targeted enforcement can address bad actors without punishing everyone else. Shutting down or over-regulating these markets would just push activity to unregulated offshore platforms, which are far less safe. I've looked at platforms like Kalshi, which operate under CFTC oversight, and it's clear to me that regulated markets are the better path. They provide transparency and accountability that you won't find in offshore alternatives.
I'm not naive about the risks, but I think the benefits outweigh them if handled right. Prediction markets democratize access to information and financial tools, and they encourage people like me to stay informed about the world. Banning or heavily restricting them would cut off those advantages for no good reason. So, I ask the CFTC to focus on balanced rules that protect consumers while allowing innovation to thrive. Let's keep these markets legal, regulated, and accessible to everyday Americans.
Thank you for considering my perspective.
Sincerely,
James Tsan
