Comment Text:
Dear Chairman and Commissioners,
My name is Stacy Murr, and I'm a trader and investor from the United States. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the idea of well-regulated prediction markets, and I want to share why I think the CFTC should focus on proportionate rules rather than heavy restrictions or outright bans.
As a trader, I've seen firsthand how prediction markets provide information you can't get anywhere else. The forecasts on elections and public events are often more accurate than polls or pundits. I rely on these prices to make informed decisions, not just for trading but for understanding the world. This isn't just useful for me; it helps everyone by improving public decision-making and price discovery. The data from these markets could even be valuable for policymakers if it's made transparent, which aligns with academic research showing how prediction markets aggregate information efficiently.
I also use these markets to hedge real risks. For example, I've traded contracts tied to election outcomes that could impact my investments or tax planning. It's no different from hedging with commodities or stocks; it's a practical tool. I know businesses use these markets too, to manage uncertainty around regulations or economic shifts. This isn't gambling. It takes research and judgment, just like any other investment.
I'm all for consumer protection, but the answer isn't to shut down these markets. Regulated platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore alternatives like Polymarket. If you over-restrict or ban prediction markets, you're just pushing people like me to less safe venues with no oversight. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. I believe those can be adapted here without resorting to broad categorical bans. Targeted rules addressing specific risks make more sense.
I want to touch on a few of your specific questions. On Question 7 under Public Interest, I think prediction markets clearly serve the public by providing better information and hedging tools, as long as regulation keeps bad actors in check. On Question 29 regarding inside information, I believe informed traders actually improve price discovery, and existing laws already ban federal employees from misusing nonpublic info. The focus should be enforcement, not prohibition.
In closing, I urge the CFTC to support proportionate regulation of prediction markets. Don't ban or over-restrict them. Keep them accessible to everyday traders like me under a framework that protects consumers without stifling innovation. Thank you for considering my input.
Sincerely,
Stacy Murr
