Comment Text:
Dear Chairman and Commissioners,
My name is Lisa Chan, and I'm a software engineer based in New York. I work in tech, where data and accurate information are everything, and that's why I'm writing to you about the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi, and I strongly support well-regulated prediction markets. They provide unique value that I, and society as a whole, benefit from every day.
As someone who deals with complex systems, I see prediction markets as a powerful tool for cutting through noise to get real insights. Their forecasts are often more accurate than polls or pundits, whether it's about elections, economic indicators, or policy changes. I've used these markets to make sense of events that impact my life and work, like potential regulatory shifts in tech. That kind of price discovery isn't just helpful for traders like me; it benefits the public, journalists, and even policymakers who need reliable signals. Beyond that, these markets let me hedge real risks. For instance, I've traded contracts tied to economic data releases that could affect my freelance consulting rates or project funding. This isn't gambling. It takes research and judgment, much like investing in stocks or futures, and it serves a clear economic purpose.
I'm also worried about what happens if we over-restrict or ban these markets. I've seen unregulated offshore platforms out there, and they're far less safe than a CFTC-registered market like Kalshi. If we push activity offshore, we lose oversight and expose people to bigger risks. The U.S. should be leading in financial innovation, not handing that edge to other countries. I believe in freedom to participate in legal, regulated markets, and I don't want to see broad categorical bans that punish everyone for the actions of a few bad actors. Proportionate regulation, targeting specific issues like manipulation or insider trading, makes more sense. On that note, I think informed trading actually improves price discovery, as long as it's within legal bounds. It benefits all participants by making prices sharper and more reflective of reality.
I'd like to address a couple of specific questions from the ANPR. On Question 8 under Public Interest, I believe prediction markets do serve the public good through better information aggregation, and the CFTC should weigh that heavily against consumer protection concerns. For Question 15 under Listed Activities, I urge you not to classify event contracts as gaming. They have legitimate uses for hedging and discovery, as I've experienced firsthand. And on Question 29 under Inside Information, I think informed traders often enhance market accuracy, provided existing laws against insider trading are enforced.
I ask you to support proportionate regulation of prediction markets. Don't ban or over-restrict them. Let regular people like me continue to participate in these valuable, regulated spaces. Thank you for considering my perspective.
Sincerely,
Lisa Chan
