Comment Text:
Dear Chairman and Commissioners,
My name is Kevin Littenberg, and I'm just a regular citizen from Texas writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive been trading on prediction markets like Kalshi and Polymarket for a while now, and I strongly support the idea of well-regulated markets that allow people like me to participate.
I got into prediction markets because they offer information you cant find anywhere else. Whether its an election outcome or an economic indicator, the prices on these platforms often cut through the noise of pundits and polls. Ive seen firsthand how they help with price discovery, not just for traders but for anyone paying attention. This kind of transparency is good for public decision-making, and I think its something we should encourage. Plus, Im not just gambling here. I put real time into researching events and data before I trade, just like I would with stocks or other investments. Calling this "gaming" doesnt make sense to me; its got a clear economic purpose, backed up by a lot of academic research Ive read about how these markets aggregate information efficiently.
I also worry about the US falling behind in financial innovation. If we over-restrict or ban prediction markets, were just pushing activity to unregulated offshore platforms, which are way less safe than something like Kalshi thats under CFTC oversight. Id rather trade on a platform where there are rules and protections in place. Banning these markets doesnt solve problems; it creates worse ones. The US should be leading the way on this stuff, not handing the advantage to other countries.
I know there are concerns about manipulation or insider trading, and I get that. But the CFTC already has strong tools to deal with those issues in other derivatives markets. Why not adapt those same safeguards here instead of broad bans? Im looking at questions 7 through 14 in your ANPR about balancing innovation with consumer protection, and I think the answer is proportionate regulation. Target the specific risks, dont shut down the whole system. And on questions 29 through 32 about inside information, Ill say this: bad actors are already breaking laws if they trade on nonpublic info. Punish them, not the rest of us.
Im asking you to support fair, targeted regulation of prediction markets. Dont ban or over-restrict them. Let regular folks like me keep participating in a legal, regulated space that benefits everyone with better information and keeps the US competitive.
Thank you for considering my input.
Sincerely,
Kevin Littenberg