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Comment for Proposed Rule 91 FR 12516

  • From: SEAN M MORRAN
    Organization(s):

    Comment No: 115346
    Date: 4/29/2026

    Comment Text:

    Dear Chairman and Commissioners,

    My name is Sean Morran, and I'm a trader and investor based in Florida. I've been actively trading on prediction markets like Kalshi for a while now, and I wanted to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets, and I hope the CFTC will craft rules that allow these markets to thrive without over-restricting them.

    As a trader, I’ve seen firsthand how prediction markets offer insights you just can’t get from polls or pundits. Whether it's an election outcome or a major public event, the prices on these platforms often cut through the noise and give a clearer picture of what’s likely to happen. This isn’t just useful for me; it’s valuable for everyone, from regular folks to policymakers who need better data for decision-making. I also use these markets to hedge personal financial risks. For example, betting on certain economic indicators helps me offset potential losses tied to my investments. This isn’t gambling, it’s a legitimate tool for managing uncertainty, much like trading stocks or futures.

    I think the government’s sudden focus on prediction markets has a lot to do with the fact that normal people like me can participate now, not just big institutions. That’s a good thing. Democratizing access means better price discovery and more accurate forecasts because more voices are in the mix. But I’m worried that over-regulation or outright bans will push this activity to unregulated offshore platforms, which are far less safe than a CFTC-registered market like Kalshi. The US should be leading in financial innovation, not handing that advantage to other countries.

    Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets clearly serve the public good through accurate forecasting and risk management. On Topic Area C (Questions 15-22), I urge you not to classify event contracts as gaming. They have real economic purposes, like hedging and price discovery. And regarding Topic Area E on inside information (Questions 29-32), I think informed trading actually improves market accuracy and benefits all participants. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. Use those instead of broad bans. Targeted, proportionate regulation is the way to go, not sweeping restrictions that punish everyone for the actions of a few.

    I’m asking you to support rules that allow prediction markets to operate under fair oversight. Don’t ban or over-restrict them. Keep the US at the forefront of financial innovation while protecting consumers through smart regulation.

    Thank you for considering my input.

    Sincerely,
    Sean Morran

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