Comment Text:
Dear Chairman and Commissioners,
My name is Sam Robinson, and I'm a lawyer based in Alabama. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi and Polymarket, I have a strong interest in seeing these markets regulated in a way that supports innovation while protecting participants. I believe prediction markets offer unique benefits to individuals, businesses, and society, and I urge the CFTC to adopt a balanced approach that fosters their growth rather than stifling them.
I've seen firsthand how prediction markets provide information thats simply not available elsewhere. Their forecasts consistently outperform polls and pundits, giving me and others better data to make informed decisions, whether its about public policy or personal finance. This aligns with the public interest questions in your ANPR, particularly Question 7 on balancing innovation and consumer protection, and Question 9 on price discovery. Beyond that, these markets allow me to hedge real financial risks tied to events like elections or economic policy changes, which can impact my legal practice and personal investments. This hedging utility, as raised in Question 10, is a legitimate economic purpose, not gambling.
I also worry about the alternative to regulated markets. Platforms like Kalshi, operating under CFTC oversight, provide a safe, transparent space for trading event contracts. If the CFTC over-restricts or bans these markets, activity will just shift to unregulated offshore platforms, as hinted at in Question 14. Thats a worse outcome for everyone, reducing oversight and increasing risks. As a lawyer, I can tell you that pushing legitimate financial activity into shadowy corners never ends well.
Additionally, event contracts shouldnt be lumped in with gaming, a concern raised in Question 15. They serve real purposes, like hedging and price discovery, much like other derivatives the CFTC regulates. Classifying them as gambling ignores their economic value. And from a broader perspective, the US should be leading in financial innovation, not ceding ground to other countries. If we over-regulate, we risk losing our edge, a point tied to Question 33 on classification and costs. Academic research, which Ive followed closely, backs this up, showing prediction markets improve information aggregation. Id encourage the CFTC to consider this data when addressing transparency in Question 40.
Im not blind to the risks, like manipulation or insider trading. But the CFTC already has tools to address these, as noted in Questions 1 and 29. Use those tools, dont ban the market. I ask that you support proportionate regulation of prediction markets, allowing law-abiding citizens like me to participate in legal, regulated platforms without driving innovation offshore.
Thank you for considering my input.
Sincerely,
Sam Robinson
