Comment Text:
Dear Chairman and Commissioners,
My name is John Barber, and I'm a trader and investor based in Oregon. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I’m writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). These markets have become an important part of how I analyze the world, sharpen my thinking, and manage my emotions under pressure. I believe they offer real value, not just to me, but to society as a whole, and I urge the CFTC to regulate them proportionately rather than imposing broad restrictions or bans.
As a trader, I’ve seen firsthand how prediction markets provide information you can’t get anywhere else. They consistently outperform polls and pundits in forecasting events like elections or economic indicators. That accuracy isn’t just helpful for traders; it’s valuable for the public, media, and even policymakers who need reliable data to make decisions. I also view these markets as a legitimate financial tool, not gambling. Trading on them requires research, judgment, and a deep understanding of real-world events, much like trading stocks or commodities. Classifying event contracts as "gaming" (as discussed in Questions 15-22) ignores their economic purpose, like price discovery and hedging, which I rely on to navigate uncertainty.
I’m also concerned about the risks of over-restriction. If the CFTC bans or overly limits these markets, activity will just move to unregulated offshore platforms, which are far less safe for consumers like me. Regulated markets, such as Kalshi on a CFTC-registered DCM, offer transparency and protection that offshore alternatives can’t match. On that note, I believe the CFTC already has strong tools to address concerns like manipulation and insider trading (relevant to Questions 1-6 and 29-32). Instead of new categorical bans, the focus should be on enforcing existing laws and creating targeted rules. Informed trading, by the way, isn’t a problem; it improves price discovery and benefits everyone in the market.
Finally, I want to stress the importance of U.S. leadership in financial innovation (as raised in Questions 7-14). We shouldn’t cede this space to other countries by over-regulating. Proportionate regulation can balance consumer protection with the freedom to participate in legal markets. Academic research backs this up, showing how prediction markets aggregate information efficiently. I urge the CFTC to consider these benefits and avoid broad restrictions that punish legitimate participants like me.
Thank you for considering my perspective. I strongly encourage the Commission to support well-regulated prediction markets with targeted, proportionate rules rather than bans or excessive limits.
Sincerely,
John Barber
