Comment Text:
Dear Chairman and Commissioners,
My name is Shelby Mowbray, and I'm writing from Washington state as an everyday citizen and the wife of a U.S. Navy member. I'm not a big trader or a financial expert, just someone who believes my money and my voice matter just as much as anyone else's. I've used prediction markets a few times, and I'm reaching out in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my support for regulated markets and my concern about over-restricting them.
I value the freedom to participate in legal, regulated markets like Kalshi, which operate under CFTC oversight. These platforms give people like me a chance to have a stake in understanding and forecasting events that affect our lives, whether it's an election outcome or an economic policy change. Honestly, it's empowering to have access to information and tools that aren't just reserved for big institutions or wealthy investors. Prediction markets provide prices and insights I can't find anywhere else, and I've seen how they often predict outcomes better than polls or pundits. That benefits everyone, not just those of us trading.
What worries me is the idea of banning or heavily restricting these markets. If that happens, people won't just stop participating. They'll turn to unregulated offshore platforms that have no oversight, no consumer protections, and no accountability. Regulated markets like Kalshi are far safer, with rules in place to prevent manipulation and ensure fairness. Pushing activity offshore by over-regulating here at home seems like a step backward, and I urge you to consider this in your responses to Questions 7 and 8 about balancing innovation and consumer protection.
I also want to raise a specific issue I've noticed. I strongly disagree with the practice of changing the names or titles of prediction markets after trades have been made. This is misleading and can completely alter the context of what people are betting on. It undermines trust in the system. I think this needs to be investigated and stopped, and I'd ask you to look at this under Question 1 regarding manipulation prevention and core principles for fair trading.
I'm not blind to the risks. I know insider trading and manipulation are concerns, but those are already illegal under existing laws. The CFTC has the tools to enforce those rules without shutting down entire markets. Banning prediction markets to stop a few bad actors feels like punishing everyone for the actions of a few.
I respectfully ask that you support proportionate regulation of prediction markets. Don't ban or over-restrict them. Keep them accessible to regular people like me under a fair, supervised framework. Thank you for considering my input.
Sincerely,
Shelby Mowbray
