Comment Text:
Dear Chairman and Commissioners,
My name is Robyn Hastings, and I'm a finance professional from the United States. I've been actively trading on prediction markets like Kalshi and Polymarket for a few years now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the development of well-regulated prediction markets, and I want to share why I believe they are valuable for individuals like me, for businesses, and for society as a whole.
As someone who works in finance, I see prediction markets as a unique tool for both forecasting and managing risk. I've used these platforms to hedge personal financial risks tied to election outcomes that could impact tax policies or regulatory changes affecting my investments. The ability to hedge against uncertainty isn't just a game, it's a practical way to protect myself from events I can't control. I know businesses do the same, using these markets to manage risks around policy shifts or economic data releases. This isn't gambling, it's a legitimate economic activity, much like trading futures or options to hedge other risks.
I also value the forecasting power of these markets. The prices often reflect a clearer picture of public events, like elections, than polls or pundits ever could. I've seen this firsthand when trading on Kalshi, where the aggregated wisdom of many traders often beats expert opinions. This kind of transparency and data isn't just useful for me as a trader, it benefits everyone by making information more accessible. Informed trading, even by those with deep knowledge, improves price discovery, and I believe that's a net positive for all participants.
I understand there are concerns about manipulation or insider trading, and I don't take those lightly. But the CFTC already has strong tools to address these issues in other derivatives markets, and they can be applied here too. Banning or over-restricting prediction markets because of a few bad actors would be a mistake. It would push activity to unregulated offshore platforms, which is far riskier for everyone. Instead, the US should lead in financial innovation, setting a global standard for how these markets can operate safely and transparently. Academic research backs this up, showing how prediction markets aggregate information efficiently, and I think the CFTC should lean on that evidence.
Specifically addressing some of your questions, I believe event contracts should not be classified as gaming (Question 15). They serve real economic purposes like hedging and price discovery, distinct from betting for entertainment. On insider trading (Questions 29-32), I think informed trading often improves market accuracy, and existing laws already prohibit misuse of nonpublic information. The focus should be enforcement, not broad bans.
I'm asking the CFTC to support proportionate regulation of prediction markets. Don't shut them down or overly restrict them. Create clear, fair rules that protect consumers while allowing innovation and participation. These markets are too valuable to lose.
Sincerely,
Robyn Hastings
