Comment Text:
Dear Chairman and Commissioners,
My name is Todd Birch, and I'm an engineer from Idaho writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm just an everyday citizen who enjoys sports and values the freedom to participate in legal, regulated markets. I'm new to prediction markets, but I strongly support their existence under fair regulation, and I hope my perspective helps shape your approach.
As someone who works hard and manages my own finances, I see prediction markets as a valuable tool, not a game or gamble. I like the idea of putting money on the outcome of a hockey game or other public events, not because it's a thrill, but because it's a way to engage with something I care about while using research and judgment. This isn't much different from investing in stocks or commodities. Classifying event contracts as "gaming" feels wrong to me; they serve real economic purposes, like hedging risks or gaining unique insights. For instance, I could see myself using these markets to hedge personal financial risks tied to public events, like policy changes affecting my job or costs. Why should I be denied that freedom when it doesn't harm anyone else?
I'm also struck by how prediction markets offer accurate forecasting for things like elections. I've read about academic research showing they often beat polls and pundits. That kind of information benefits everyone, not just traders. Plus, informed trading makes prices more accurate, which helps the whole market. I don't understand why there's so much concern over what I do with my own money. My trades are tracked, taxes are paid through 1099 forms, and no one else's rights are affected. If anything, banning or over-restricting these markets feels like an infringement on my personal freedom. Why push me toward undesirable alternatives like offshore, unregulated platforms or even casinos on reservations or in places like Vegas? Regulated markets like Kalshi are safer, transparent, and keep activity here in the US. If we over-regulate, we're just ceding financial innovation to other countries. The US should be a leader, not a follower.
I appreciate that there are concerns about manipulation or insider trading, but the CFTC already has strong tools to handle those issues. Use them. Don't punish law-abiding folks like me by shutting down entire markets. In response to some of your questions, like those in Topic B on public interest (Questions 7-14), I urge you to balance innovation with protection by focusing on targeted rules, not broad bans. And for Topic C on listed activities (Questions 15-22), please don't label these contracts as gaming when they have clear economic value.
If the goal is truly to protect Americans, then support proportionate regulation of prediction markets. Don't ban or overly restrict them. Keep them safe, legal, and accessible right here at home.
Sincerely,
Todd Birch
