Comment Text:
Dear Chairman and Commissioners,
My name is Jake Gorgol, and I'm a trader and investor based in South Carolina. I'm writing in response to 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, as well as to society at large, and I urge the CFTC to craft rules that encourage innovation while addressing legitimate risks.
As a trader, I've seen firsthand how prediction markets offer insights you just can't get from polls or pundits. For elections and other public events, these markets have consistently been more accurate in forecasting outcomes. That information isn't just helpful for me when I trade; it's valuable for everyone, from journalists to policymakers, who need reliable data to make sense of the world. Beyond forecasting, I've used these markets to hedge personal financial risks tied to political and economic events. For example, trading on election outcomes helps me manage uncertainties that could impact my investments or taxes. This isn't gambling. It's a practical tool, much like trading stocks or futures, requiring research and real-world judgment.
I'm also concerned about access and safety. Regulated platforms like Kalshi, operating under CFTC oversight, provide a secure environment with clear rules. If we over-restrict or ban these markets, people will just turn to unregulated offshore platforms, which are far riskier and lack accountability. I've traded on both types of platforms, and the difference in transparency and reliability is night and day. Keeping these markets regulated here in the US is the best way to protect participants and maintain trust.
On a broader level, I believe the US should be a leader in financial innovation. Prediction markets are a growing field, and if we stifle them with heavy-handed rules, we'll cede ground to other countries that are more willing to embrace new ideas. Academic research, which I've followed closely, backs this up. Studies by economists like Hanson and Wolfers show how these markets aggregate information efficiently, benefiting everyone with better data transparency.
Id like to address a few specific questions from the ANPR. Regarding Questions 7-14 on public interest, I think the CFTC should prioritize balancing innovation with consumer protection by focusing on targeted rules rather than broad bans. For Questions 15-22 on listed activities, I believe event contracts should be defined by their economic purpose, like hedging or price discovery, not mislabeled as gaming. And on Questions 33-40 about costs and benefits, I urge you to consider how over-regulation could burden small traders like me while pushing activity to less safe venues.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Focus on using existing tools to combat manipulation and insider trading, and let these markets grow under fair oversight. Thank you for considering my input.
Sincerely,
Jake Gorgol
