Comment Text:
Dear Chairman and Commissioners,
My name is Noah Robinson, and I'm a trader and investor based in North Carolina. Ive been actively trading on prediction markets like Kalshi and Polymarket for a while now, and Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support well-regulated event contracts and believe the CFTC has a chance to get this right with proportionate rules, not heavy-handed restrictions.
As a trader, Ive seen firsthand how prediction markets provide information you just cant get anywhere else. Their forecasts on elections and public events are often more accurate than polls or pundits. Ive used these insights to make better decisions, not just in trading but in understanding the world around me. This isnt gambling, no matter what some might say. Trading on these platforms takes research and judgment, just like trading stocks or commodities. Classifying event contracts as "gaming" ignores their real economic purpose, like price discovery and hedging. I urge the CFTC to recognize this distinction when addressing questions like 15 and 16 on listed activities.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If the CFTC bans or over-restricts these markets, people like me will get pushed to less secure venues. Thats not consumer protection; its the opposite. On questions 7 and 8 about public interest, I believe regulation should balance innovation with safety, not shut down legitimate markets. The US should be leading in financial innovation, not handing that advantage to other countries.
I know there are concerns about manipulation and insider trading. I get it, those are real risks. But the CFTC already has strong tools to tackle these issues in other derivatives markets. Use those same powers here. Dont punish honest traders by banning entire categories of contracts. Thats not the answer. Id point to questions 29 and 30 on inside information, where I think the focus should be on enforcing existing laws, not creating new barriers.
Im asking the CFTC to support proportionate regulation of prediction markets. Target the specific risks with clear rules, but dont over-restrict or ban these valuable tools. Theyre not just useful for traders like me; they benefit society by producing better information and giving regular people a stake in understanding public events. Lets keep this innovation alive in a safe, regulated way.
Thank you for considering my input.
Sincerely,
Noah Robinson
