Comment Text:
Dear Chairman and Commissioners,
My name is Courtney Keener, and I'm an everyday citizen from Colorado. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I believe they have real value for people like me. I wanted to share my thoughts on why these event contracts shouldn't be treated as gambling and why they serve important economic purposes.
When I first tried prediction markets, I was surprised by how much thought and research went into making decisions. It's not a game of chance. I had to read up on current events, think about trends, and make judgments based on real-world information. To me, that's no different from investing in stocks or other financial markets. Calling this "gaming" feels wrong because it ignores the skill and effort involved. These markets also provide unique insights that I can't find anywhere else, like forecasts on economic or political events that affect my life. That kind of information benefits everyone, not just traders.
I also see real economic value in event contracts. They aren't just for fun; they can help people manage uncertainty. For example, if I'm worried about how a policy change might impact my cost of living here in Colorado, a prediction market could let me hedge against that risk. That's a practical use, not gambling. I think the CFTC should recognize this distinction when considering how to define and regulate these contracts, especially in response to Questions 15-22 about listed activities and the gaming label.
That said, I do have concerns about some specific markets. I've noticed issues with certain prediction markets on entertainment outcomes, like Netflix top show or movie bets. Often, the leading contender seems to pop up just a day or two before the result, which feels suspicious. It's frustrating as a user, and it's turned me away from those platforms. Plus, the rules for something like a "top 10 Netflix" list aren't clear at all, leaving bettors confused. I think the CFTC should look into transparency and fairness for these specific contracts, maybe under Questions 1-6 on core principles like manipulation prevention.
Still, these problems don't mean prediction markets as a whole should be banned or over-regulated. Bad actors or poorly designed contracts shouldn't punish everyone. The CFTC already has tools to tackle manipulation and unfair practices, and I believe those can be applied here without throwing out the good with the bad.
I'm asking you to support proportionate regulation of prediction markets. Recognize their legitimate economic purposes, don't label them as gaming, and focus on targeted rules to address specific issues like transparency. That way, regular people like me can keep benefiting from these tools.
Thank you for considering my input.
Sincerely,
Courtney Keener
