Comment Text:
Dear Chairman and Commissioners,
My name is Phil Dwyer, and I'm a regular citizen from Massachusetts who actively trades on prediction markets like Kalshi and Polymarket. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the development of well-regulated prediction markets in the United States, and I want to share why I believe they are valuable for people like me and for society as a whole.
I've been trading on these platforms for a while now, and I've seen firsthand how they provide information you can't get anywhere else. The forecasts on prediction markets are often more accurate than polls or pundits, which helps me make better decisions, whether it's about personal finances or just understanding what's likely to happen in politics or the economy. This isn't just good for traders; it's good for everyone when better information is out there for public decision-making. I also use these markets to hedge real risks. For example, I've placed trades to offset uncertainties around election outcomes that could impact my taxes or local business regulations. This isn't gambling. It takes research and judgment, just like investing in stocks.
I know there are concerns about things like insider trading or manipulation, and I get that. But banning or over-restricting these markets isn't the answer. The CFTC already has tools to tackle bad actors, and those should be used instead of punishing everyone. I'm also worried that heavy-handed rules will push activity to unregulated offshore platforms, which are far riskier for consumers like me. I've traded on Kalshi, a regulated market, and the transparency and oversight there make me feel much safer. If the US over-regulates, well lose that protection and cede leadership in financial innovation to other countries. We should be leading the way, not falling behind.
Regarding some of the specific questions in the ANPR, I want to address a few points. On Questions 7-14 about public interest, I believe prediction markets serve a clear public good through price discovery and risk management. Informed trading, as raised in Questions 29-32, actually improves price accuracy and benefits all participants, so long as existing laws against insider trading are enforced. And on Questions 15-22 about listed activities, I strongly feel event contracts shouldn't be labeled as gaming. They have legitimate economic purposes, like hedging and forecasting, that set them apart.
I urge the CFTC to adopt proportionate, targeted regulations rather than broad bans or restrictions. Focus on specific risks with clear rules, and let regular people like me continue to participate in these legal, regulated markets. Thank you for considering my perspective.
Sincerely,
Phil Dwyer
