Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Valerie, Kosiadi
Valerie KosiadiSupportIndividual
Summary: The commenter, an Engagement Manager in fintech, argues that the Commission should distinguish between commercial prediction markets and nonprofit research markets in its regulatory framework. They suggest that a one-size-fits-all approach could unfairly burden smaller research entities and advocate for tailored controls based on a market's specific purpose and risk profile.
As an Engagement Manager working in fintech and identity verification, I have seen how regulatory and compliance requirements shape who can participate in a market. In identity verification, the goal is not to add friction for its own sake. The goal is to apply the right level of controls for the risk presented. Across fintech operations, effective compliance programs have to balance fraud prevention, user access, operational feasibility, and the practical cost of implementation.
That experience informs my view on Question 11. In considering fair competition with respect to prediction markets, the Commission should consider whether its framework preserves fair competition not only among commercial platforms, but also between commercial platforms and nonprofit research markets that serve a different public-interest function. A one-size-fits-all framework can unintentionally favor larger commercial actors with more capital, more compliance staff, and stronger incentives to absorb regulatory burden as a cost of market entry. By contrast, nonprofit research markets may serve a public knowledge function without the same commercial incentives, scale, or risk profile.
Nonprofit research prediction markets should be recognized as distinct from commercial prediction-market platforms. In my view, markets designed to produce public knowledge should not automatically be treated the same as platforms designed to maximize trading volume, entertainment value, or commercial participation. The Commission can still require appropriate controls for market integrity, fraud prevention, transparency, and participant protection, but those controls should be tailored to the market s purpose, structure, and actual risk.
A fair-competition framework should avoid treating every prediction market as though it presents the same incentives, risks, and commercial purpose. If nonprofit research markets are required to satisfy the same operational and compliance burdens as large commercial or sports-adjacent platforms, the practical result may be less competition, less experimentation, and less public-interest research. I encourage the Commission to consider a framework that protects market integrity while preserving space for nonprofit research markets to operate as research infrastructure.