Comment Text:
Dear Chairman and Commissioners,
My name is Jason Fulton, and I'm a software engineer from Arizona. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi and Polymarket, I've seen firsthand the value these markets bring, and I believe the CFTC has a real opportunity to foster innovation while protecting consumers.
Prediction markets aren't just a niche hobby for me; they provide unique insights you can't get from polls or pundits. I've found their forecasts on elections and public events to be consistently more accurate, which helps me make better-informed decisions, both personally and in my tech career where policy shifts can impact my work. Beyond that, these markets let me hedge real financial risks. For instance, I've used them to offset uncertainties around economic policies that could affect my income or business prospects. This isn't gambling, it's a legitimate tool for managing risk and accessing information.
I also believe that event contracts serve a clear economic purpose, like price discovery and risk management, and shouldn't be labeled as gaming. Trading on these platforms requires research and judgment, much like trading stocks. Calling it gambling dismisses the skill and value involved. Plus, informed traders, who often know their subjects deeply, improve the accuracy of prices, which benefits everyone, not just those trading. We need more markets like this, with diverse options, so people from all walks of life can participate and trade on what they know.
I'm concerned, though, about the risk of over-restriction or outright bans. If the CFTC clamps down too hard, it will just push activity to unregulated offshore platforms, which are far less safe than regulated markets like Kalshi. The US should be leading in financial innovation, not ceding ground to other countries. I've read academic research showing how prediction markets aggregate information efficiently, and I think the CFTC should lean on that data to craft smart, targeted rules rather than broad prohibitions.
Specifically, on some of the questions in the ANPR, Id like to address a few points. On Questions 7-14 under Public Interest, I think the balance between innovation and consumer protection lies in supporting regulated markets that give everyday people access to these tools while using existing safeguards against manipulation. On Questions 15-22 about Listed Activities, I urge you not to classify event contracts as gaming; theyre distinct in purpose. And on Questions 29-32 regarding Inside Information, I believe informed trading enhances price discovery, and existing laws already cover insider trading abuses.
I understand there are concerns about manipulation or insider risks, but the CFTC already has powerful tools to tackle those issues without banning entire markets. Please focus on proportionate regulation that addresses specific risks while allowing these valuable markets to grow. Let's keep the US at the forefront of financial innovation.
Thank you for considering my input.
Sincerely,
Jason Fulton