Comment Text:
Dear Chairman and Commissioners,
My name is Ryan Manning, and I'm a trader and investor based in Florida. I graduated from the University of Florida, where we often used prediction market data in our classes to analyze trends and forecasts. Now, as a full-time professional, I've participated in prediction markets a few times myself. I'm writing to express my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value, both to individuals like me and to society at large, and I urge the CFTC to craft proportionate regulations rather than overly restrictive rules.
I first saw the power of prediction markets back in college. Wed pull data from platforms to compare their election forecasts against polls and pundits, and the markets were almost always more accurate. That stuck with me. Now, as someone managing my own investments, I see these markets as a unique tool for hedging risks tied to public events, like elections or policy changes that could impact my taxes or portfolio. This isnt gambling. It takes research and judgment, just like trading stocks or futures. Labeling event contracts as "gaming" ignores their real economic purpose, as raised in Questions 15-22 of your ANPR.
I also believe regulated markets, like Kalshi on a CFTC-registered DCM, are far safer than the unregulated offshore platforms people turn to when access is restricted. Banning or over-regulating these markets just pushes activity into riskier spaces with no consumer protections. Id rather see the US lead in financial innovation than cede that edge to other countries. Your Questions 7-14 on balancing innovation and protection really hit on this, and I think regulation is the answer, not prohibition.
On the issue of manipulation and insider trading, brought up in Questions 29-32, Im not naive to the risks. But the CFTC already has strong tools to tackle these problems in other derivatives markets. Use those tools here instead of broad bans. Plus, informed trading often improves price discovery, which benefits everyone, not just traders. Academic research backs this up, showing how prediction markets aggregate information efficiently. I value that transparency as someone who relies on accurate data.
Im not saying there shouldnt be oversight. I want consumer protections in place. But shutting down or severely limiting prediction markets punishes regular folks like me who use them responsibly. It also risks stifling a tool that helps us all understand the world better. I ask the CFTC to support proportionate regulation that addresses specific risks without undermining the benefits of these markets. Lets keep them legal, safe, and accessible on regulated platforms in the US.
Thank you for considering my input.
Sincerely,
Ryan Manning
