Comment Text:
Dear Chairman and Commissioners,
My name is Jeremy Silverman, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing to express my strong support for proportionate regulation of these markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these platforms provide unique value to individuals like me and to society as a whole, and I urge the CFTC to foster their growth with sensible rules rather than restrictive bans.
As a trader, Ive seen firsthand how prediction markets produce forecasts that often beat polls or pundits. Whether its an election outcome or a major policy shift, the aggregated wisdom of market participants gives me insights I cant get anywhere else. This isnt just helpful for my own decisions; its valuable for the public, media, and even policymakers who need accurate data to guide their choices. Ive relied on these markets to better understand trends that impact my investments, and I know many others do too.
I also want to stress that event contracts arent gambling. They serve real economic purposes, like price discovery and risk management. Trading on Kalshi requires research and judgment, much like trading stocks or commodities. Labeling this as gaming would be a misstep. Plus, having access to regulated markets like Kalshi is far safer than the alternative of unregulated offshore platforms. If the CFTC over-restricts or bans these markets, it will push activity to less transparent venues, which helps no one.
Im particularly drawn to the academic research backing prediction markets. Studies by economists like Hanson and Wolfers show how these markets improve information aggregation. Informed trading isnt a flaw; its a feature that enhances price discovery and benefits all participants. Addressing the CFTCs questions 29-32 on inside information, I believe the focus should be on enforcing existing laws against insider trading rather than limiting the markets themselves. The tools are already there; use them.
Finally, the U.S. should be a leader in financial innovation. We shouldnt cede this space to other countries by over-regulating. In response to questions 7-14 on public interest, I think balancing innovation with consumer protection means supporting regulated platforms while addressing specific risks with targeted rules, not broad prohibitions.
I ask the CFTC to support the continued growth of prediction markets with fair and proportionate regulation. These markets provide unique forecasting tools, improve public decision-making, and offer democratized access to valuable information. Lets keep them accessible and safe under your oversight, without stifling their potential.
Thank you for considering my input.
Sincerely,
Jeremy Silverman
