Comment Text:
Dear Chairman and Commissioners,
My name is Joshua Rawlins, and Im a small business owner based in the District of Columbia. Im writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive been an active trader on platforms like Kalshi, and I strongly support the idea of well-regulated prediction markets. I believe they serve a valuable purpose for individuals like me, and for society as a whole, and Im concerned about overly restrictive rules that could push this activity into less safe spaces.
As a business owner, Im always looking for reliable information to help me plan. Prediction markets have been a game-changer in that regard. They give me a clearer picture of what might happen with elections or other public events that directly impact my business, from tax policy shifts to regulatory changes. The forecasts on these platforms often seem more accurate than what I hear from pundits or see in polls. Honestly, before I started trading on Kalshi, I found it easy to tune out current events and just be a bystander. But putting a small stake in these markets has made me pay attention, do my research, and stay engaged. Thats a benefit I didnt expect, and I think its good for civic participation.
I want to be clear that I dont see this as gambling. Trading on event contracts takes real thought and judgment, much like investing in stocks. Its about assessing real-world outcomes, not just rolling dice. Classifying these contracts as gaming, as discussed in Questions 15-22 of the ANPR, doesnt fit. They serve a legitimate economic purpose, whether its hedging risks tied to policy changes or gaining insights from aggregated information. I urge the CFTC to recognize this distinction.
I also worry about what happens if these markets are banned or over-restricted. Right now, trading on a regulated platform like Kalshi feels safe. I trust theres oversight. But if heavy-handed rules push these markets out of reach, people like me will look for alternatives, likely offshore platforms with no protections. Thats a worse outcome for consumer safety, which ties into Questions 7-14 on public interest and consumer protection. Regulation should keep activity in the US, under CFTC oversight, not drive it away.
Lastly, I believe the US should be a leader in financial innovation. We cant afford to fall behind other countries by stifling these markets. As for concerns like manipulation or insider trading, I get that theyre real issues. But the answer, as raised in Questions 29-32, isnt to shut things down. Its to use the tools the CFTC already has and craft targeted rules, not broad bans that punish everyone.
I respectfully ask the CFTC to support proportionate regulation of prediction markets. Keep them legal and accessible under clear, fair rules. Dont let over-restriction push this valuable tool out of reach for regular people like me.
Sincerely,
Joshua Rawlins
