Comment Text:
Dear Chairman and Commissioners,
My name is Wensi Pan, and I'm an everyday citizen from California writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I believe strongly that well-regulated prediction markets offer real value to people like me and to society as a whole. I appreciate the chance to weigh in on how the CFTC can approach this growing space.
I rely on prediction markets for insights that I just can't get from polls or pundits. Time and again, these markets have proven more accurate in forecasting elections and other public events. That kind of information isn't just helpful for traders; it's useful for anyone trying to make sense of the world. Beyond that, these markets let me hedge personal financial risks. For instance, I've used them to offset uncertainties around economic policies that could impact my budget or savings. This isn't gambling. It takes research and judgment, much like any other investment I make.
I'm also concerned about freedom to participate. As a regular person, I value having access to these markets on regulated platforms like Kalshi, which operate under CFTC oversight. If we ban or over-restrict these markets, activity will just move to unregulated offshore sites, which are far less safe for consumers like me. Regulation, not prohibition, is the answer. The U.S. should be leading in financial innovation, not handing that advantage to other countries. I want to see the CFTC build a framework that keeps us competitive while protecting participants.
Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets support price discovery and risk management in ways that benefit everyone, not just traders. On Topic Area C (Questions 15-22), I urge you not to classify event contracts as gaming. They serve real economic purposes, like hedging and forecasting, and shouldn't be lumped in with gambling. And regarding Topic Area E on inside information (Questions 29-32), I think informed trading actually improves price discovery. The CFTC already has strong tools to tackle manipulation and insider trading in other markets; those can be applied here without resorting to broad bans.
I know there are legitimate concerns about manipulation or unfair advantages, but punishing everyone by shutting down or overly restricting these markets isn't the solution. Targeted, proportionate regulation can address specific risks while preserving the benefits. I hope the CFTC will support a balanced approach that allows prediction markets to thrive under clear, fair rules.
Thank you for considering my perspective.
Sincerely,
Wensi Pan
