Comment Text:
Dear Chairman and Commissioners,
My name is Bryce McKinnon, and I'm a student from Delaware. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi and Polymarket, and I believe these markets provide real value to people like me and to society as a whole. I want to urge the CFTC to support well-regulated prediction markets rather than restricting or banning them.
As a student, I find prediction markets incredibly useful for learning about the world. They're not just a way to make a few bucks; they help me understand complex events by putting real stakes on my research and judgment. I've traded contracts tied to election outcomes and economic indicators, and doing so forces me to dig into data, read up on policy, and think critically about what's likely to happen. This isn't gambling. It's a process that mirrors the kind of analysis I'd do for a term paper or a class discussion, except the feedback is immediate and tied to real-world accuracy. I believe this kind of engagement is valuable for anyone, not just academics or big investors.
Im particularly concerned about the idea of classifying event contracts as "gaming," as discussed in questions 15 through 22 of the ANPR. These contracts serve legitimate economic purposes, like price discovery and hedging. For example, I've used them to offset risks related to policy changes that could affect my future job prospects or student loan rates. If I can trade on an election outcome or a Federal Reserve decision, Im better prepared to plan my finances. Thats not a game; its a practical tool. Labeling these contracts as gambling ignores their real utility and risks pushing them into unregulated spaces where theres less oversight.
I also recognize the CFTCs concerns about manipulation or insider trading, as raised in questions 29 to 32. Those are valid worries, but the solution isnt to shut down prediction markets. Insider trading and market manipulation are already illegal, and the CFTC has the authority to enforce those rules. Punishing everyone by banning or over-restricting these markets because of a few bad actors doesnt make sense. Its like closing a library because someone might steal a book. Instead, focus on targeted enforcement and clear guidelines to keep things fair.
Prediction markets are a powerful way to aggregate information and help regular people like me engage with the world. I urge the CFTC to regulate them proportionately, ensuring they remain accessible while addressing specific risks with existing tools. Please dont let broad restrictions or misclassifications as gaming undermine their potential.
Thank you for considering my perspective.
Sincerely,
Bryce McKinnon
