Comment Text:
Dear Chairman and Commissioners,
My name is G. Thomas Sahn, and Im a trader and investor based in Connecticut. Im writing to share my honest 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 strongly support the development of well-regulated prediction markets in the United States.
Ive seen firsthand how these markets provide unique value. Theyre not just a way to place bets; they offer real economic utility through price discovery and risk management. For instance, Ive used event contracts to hedge personal financial risks tied to economic indicators and policy outcomes. This isnt gambling. It takes research and judgment, much like trading stocks or futures. Classifying these contracts as gaming would be a misstep, as they serve legitimate purposes that benefit individuals and the broader economy. I urge the CFTC to recognize this distinction when addressing questions like those in Topic Area C (Questions 15-22) about defining gaming versus legitimate markets.
I also believe the U.S. must lead in financial innovation. Prediction markets are the next step in how we process information and allocate capital. If we over-restrict or ban them, we risk pushing this activity to offshore platforms with little oversight, which hurts consumers more than it helps. Id rather see regulated markets here, like Kalshi on a CFTC-registered exchange, than drive traders to less safe alternatives. This ties directly to Topic Area B (Questions 7-14) on balancing innovation with consumer protection. Regulation, not prohibition, is the answer.
On the issue of insider trading or manipulation, I understand the concern. But broad categorical bans arent the solution. Informed trading actually improves price discovery, benefiting everyone by making market signals clearer. The CFTC already has tools to tackle manipulation and insider trading in other derivatives markets, and those can be adapted here. Lets focus on targeted rules instead of punishing all participants for the actions of a few. This relates to Topic Area E (Questions 29-32) on inside information and its role in markets.
Ive always believed our economy thrives when we embrace new ideas, not stifle them. Prediction markets are a powerful tool for democratizing information and managing uncertainty. I ask the CFTC to support proportionate regulation that addresses specific risks without shutting down this innovative space. Lets keep the U.S. competitive and ensure traders like me can participate in legal, regulated markets.
Thank you for considering my perspective.
Sincerely,
G. Thomas Sahn
