Comment Text:
Dear Chairman and Commissioners,
My name is Samuel Duggan, and I'm a healthcare professional from Georgia. I'm writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I believe these markets provide real value, both to me personally and to society as a whole. I want to share why I think the CFTC should support proportionate regulation rather than restrictive bans or overregulation.
As someone who works in healthcare, I often deal with uncertainty, whether it's about policy changes affecting my field or economic shifts impacting my patients. Prediction markets have given me a unique tool to better understand and navigate these uncertainties. The prices on these platforms often provide insights that I can't find in polls or news punditry. I've seen firsthand how they consistently outpredict so-called experts on election outcomes or economic indicators. This isn't just helpful for traders like me; its valuable information for everyone, from policymakers to regular citizens trying to make sense of the world.
I also want to push back on the idea that event contracts are gambling. I put time and thought into my trades, researching data and trends, much like I would for any investment. These markets aren't a game of chance; they serve real economic purposes like price discovery and even hedging against risks. For example, Ive used them to offset potential financial hits from policy changes that could affect healthcare costs. Calling this "gaming" feels like a misstep when its clearly a legitimate market activity. I hope the CFTC considers this perspective when addressing questions 15 through 22 on listed activities and the definition of gaming.
Another point I feel strongly about is the role of informed trading. I believe traders with good information actually improve price accuracy, which benefits everyone. Banning or overly restricting these markets because of concerns about insider trading, as raised in questions 29 to 32, would be a mistake. The CFTC already has tools to tackle manipulation and insider trading in other markets. Use those tools here instead of punishing all participants. Plus, regulated markets are far safer than unregulated offshore platforms. If the US steps back, we risk ceding leadership in financial innovation to other countries. We should be at the forefront, not playing catch-up.
I urge the CFTC to craft rules that allow regular people like me to keep participating in these legal, regulated markets. Focus on targeted solutions for specific risks rather than broad restrictions. Prediction markets are a powerful tool for better information and decision-making, and I hope youll support their growth with fair regulation.
Sincerely,
Samuel Duggan
