Comment Text:
Dear Chairman and Commissioners,
My name is Jared Gavel, and I'm a trader and investor based in California. I'm writing to provide my input on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to individuals like me and to society as a whole, and I hope the CFTC will craft rules that allow these markets to thrive while addressing legitimate risks.
As a trader, I rely on prediction markets for information that I simply can't get elsewhere. Their forecasts on elections and public events have consistently proven more accurate than polls or pundits. I use this data to inform my decisions, both personal and financial, and I know others do too. Beyond forecasting, these markets let me hedge risks that impact my investments and personal finances, like policy changes or economic shifts tied to election outcomes. This isn't gambling, in my view. Trading on these platforms requires research and judgment, much like trading stocks or other securities. The economic purpose, whether it's price discovery or hedging, sets event contracts apart from gaming.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, offer transparency and consumer protection that unregulated offshore alternatives can't match. Banning or over-restricting prediction markets won't eliminate demand, it will just push activity to less safe venues where there's no accountability. I'd much rather see the CFTC regulate these markets proportionately, using the robust tools it already has to combat manipulation and insider trading. New bans aren't necessary when existing laws can address bad actors without punishing everyone else.
Regarding some of the specific questions in the ANPR, Id like to touch on a couple that resonate with me. On Question 8, about the public interest benefits of prediction markets, I believe their ability to aggregate information and produce accurate forecasts serves everyone, not just traders. On Question 15, regarding the definition of gaming, I urge the CFTC to recognize that event contracts serve legitimate economic functions and shouldn't be lumped in with gambling. And on Question 29, about inside information, I think the CFTC's existing enforcement powers are enough to deter abuse without broad prohibitions that could stifle these markets.
I've read academic research showing how prediction markets improve information transparency, and I think the US should lead in this space, not cede it to others. I ask that the CFTC support proportionate regulation that protects consumers while allowing innovation and participation in prediction markets. Please don't let over-restriction or outright bans push this valuable tool offshore.
Thank you for considering my perspective.
Sincerely,
Jared Gavel