Comment Text:
Dear Chairman and Commissioners,
My name is Zachary Fields, and I'm a finance professional from Tennessee. Im writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi and Polymarket, and I strongly support the development of well-regulated prediction markets in the United States.
As someone who works in finance, I rely on accurate information to make decisions, and Ive found prediction markets to be an incredible tool for forecasting events like elections and other public outcomes. Time and again, these markets have proven more accurate than polls or pundits. Ive seen firsthand how the aggregated wisdom of many traders can cut through noise and bias to provide clear signals about whats likely to happen. This isnt just useful for me; its valuable for society as a whole, from businesses planning for policy changes to regular folks trying to understand the world.
I also believe in the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, provide a safe and transparent space for trading event contracts. Ive traded on both regulated and unregulated platforms, and the difference is night and day. Unregulated offshore sites lack accountability, and if the CFTC over-restricts or bans prediction markets here, thats where activity will go. Its not hard to imagine thousands of Americans, including myself, being pushed to less safe venues. Thats the opposite of consumer protection.
Im aware of concerns about manipulation or insider trading, and I get why those are issues to watch. But the CFTC already has strong tools to address these problems in other derivatives markets. Those same tools can be adapted here without resorting to broad bans or heavy-handed rules. Shutting down prediction markets to stop a few bad actors makes no sense to me; its like closing a highway because some people speed.
Id also like to address a couple of specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think the US has a chance to lead in financial innovation. If we over-regulate, we risk ceding that leadership to other countries. And on Question 29, regarding inside information, I believe informed traders often improve price discovery, as long as existing laws against insider trading are enforced.
Prediction markets arent gambling. Theyre a legitimate way to hedge risks and gain insight. I urge the CFTC to craft proportionate regulations that address specific risks without stifling this emerging market. Lets keep these platforms safe, transparent, and accessible to Americans like me who value their potential.
Thank you for considering my input.
Sincerely,
Zachary Fields