Comment Text:
Dear Chairman and Commissioners,
My name is Jordan Duncan, and I'm just a regular person from Minnesota writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm not an expert or a big investor, just someone who has found value in prediction markets and wants to see them regulated sensibly, not banned or overly restricted.
I've been using platforms like Kalshi for a while now, especially for sports prediction markets. Last NFL season, I decided to give it a shot, and it completely changed how I engaged with the games. I didn't win every week, but I was so much more invested in the season than ever before. During the off-season, I even learned about the music industry and how the Billboard 100 works through trading on related contracts. It was eye-opening. Before Kalshi, other systems never made sense to me, and I stayed away. But with a regulated platform, I feel safer participating. If regulated U.S. options like this ceased to exist, I wouldn't touch prediction markets at all. I wouldn't trust offshore alternatives. How do I know they're any more regulated in a foreign country? I'd just stop altogether.
I believe prediction markets aren't gambling. They're about research and judgment, much like trading stocks. They also have real economic value. For me, it's not just about sports or music; I can see how people use these markets to hedge personal or business risks, like protecting against policy changes or economic shifts that impact their lives. Banning or over-restricting these markets would push activity to unregulated offshore platforms, which is far riskier for consumers like me. Regulation, not prohibition, is the way to protect us.
I'm particularly interested in a few of the questions you raised in the ANPR. On Question 7, about balancing innovation and consumer protection, I think regulated markets like Kalshi strike the right balance by offering transparency and oversight. On Question 15, regarding defining gaming versus legitimate markets, I strongly feel event contracts serve real purposes beyond just betting; they're about information and hedging. And on Question 29, about informed trading, I believe it helps improve price discovery, making the markets more accurate for everyone, not just traders.
I worry that broad categorical bans or harsh rules would hurt regular people like me who benefit from these markets while doing little to stop bad actors whod just go offshore. The CFTC already has tools to tackle manipulation and insider trading. Use those instead of punishing everyone.
Please support proportionate regulation of prediction markets. Keep platforms like Kalshi accessible under clear, fair rules that protect consumers without stifling innovation or pushing activity to unsafe venues. Thank you for considering my perspective.
Sincerely,
Jordan Duncan
