Comment Text:
Dear Chairman and Commissioners,
My name is Michele Brunngraber, and I'm a small business owner and retired engineer from Virginia. As someone who values technology and innovation, and enjoys finding legal ways to engage with markets for both entertainment and insight, Im 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). Ive been actively trading on platforms like Kalshi, and I believe these markets offer real value, both to me personally and to society, as long as theyre properly overseen by the CFTC.
I care deeply about having the freedom to participate in legal, regulated markets. As a tech-savvy individual, I see prediction markets as a unique tool that aggregates information in ways polls and pundits often cant match. Trading on Kalshi has given me a way to test my judgment on real-world events, whether its an election outcome or an economic indicator, while also providing a bit of fun. But beyond entertainment, I believe these markets help everyday people like me access insights that would otherwise be locked away with big institutions. Thats a democratizing force, not something to restrict.
Im not blind to the concerns about manipulation or insider trading, and I appreciate the CFTCs focus on protecting consumers. However, I strongly believe the answer isnt to ban or over-restrict these markets. The CFTC already has powerful tools to prevent manipulation and insider trading in other derivatives markets. Those same tools can be applied here. Shutting down or overly limiting prediction markets would just push activity to unregulated offshore platforms, which are far riskier for people like me. Id much rather trade on a regulated U.S. platform like Kalshi, where theres oversight, than be forced to seek out shadier alternatives.
I also think the U.S. should be a leader in financial innovation. If we over-regulate or ban these markets, were handing the future of this technology to other countries. Thats not just bad for American traders; its bad for our economy and global standing. Addressing specific questions in the ANPR, like those in Topic Area B on balancing innovation and consumer protection (Questions 7-14), I urge you to prioritize rules that foster innovation while targeting specific risks with existing enforcement powers. And on Topic Area E regarding insider trading concerns (Questions 29-32), I believe the focus should be on enforcing current laws rather than broad prohibitions that punish law-abiding participants.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Dont ban or over-restrict them. Keep platforms like Kalshi accessible to everyday citizens under clear, fair rules that protect us without stifling opportunity. Thank you for considering my perspective.
Sincerely,
Michele Brunngraber
