Comment Text:
Dear Chairman and Commissioners,
My name is Dylan Kellner, and I'm just a regular citizen from Texas writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm new to prediction markets, but I've taken the time to learn about them, and I strongly support their development under fair, well-thought-out regulation by the CFTC.
I believe prediction markets offer something valuable that we don't get elsewhere. They provide better information for public decision-making by aggregating what people really think, often more accurately than polls or talking heads on TV. This kind of price discovery isn't just for traders; it helps everyone, from regular folks like me to policymakers trying to gauge public sentiment. I also see these markets as a way for everyday Americans to participate in legal, regulated financial spaces. Shutting that door or over-restricting access feels like it takes away a freedom we should have, especially when the alternative is pushing activity to shady offshore platforms with no oversight.
I'm all for consumer protection, but I think the answer lies in smart regulation, not bans. Platforms like Kalshi, operating under CFTC rules, are a much safer bet than unregulated sites overseas. If the CFTC clamps down too hard, people won't stop trading; they'll just go where there's no accountability. The U.S. should be leading the way on financial innovation, not handing that advantage to other countries. We have the chance to set the standard here.
I also want to address the idea that event contracts are gambling. I don't see it that way. These contracts serve real economic purposes, like hedging against uncertainty or gaining insight into future events. Academic research backs this up, showing how prediction markets improve transparency and data aggregation. And let's not forget, the CFTC already has strong tools to handle manipulation and insider trading in other markets. Those same tools can work here without resorting to heavy-handed restrictions.
Looking at some of the specific questions in the ANPR, I think Question 7 on balancing innovation with consumer protection is key. Regulation should focus on safeguarding participants while allowing these markets to grow. Question 15, about defining gaming versus legitimate markets, also matters to me; these contracts aren't just games, and they shouldn't be treated as such. I'd urge the CFTC to look at the economic value they bring.
In closing, I ask that you support proportionate regulation of prediction markets. Don't ban or over-restrict them. Keep them safe and accessible under CFTC oversight, and let the U.S. stay at the forefront of this space. Thanks for considering my perspective.
Sincerely,
Dylan Kellner
