Comment Text:
Dear Chairman and Commissioners,
My name is Jacob Benish, and I'm just a regular guy from Wisconsin who cares about having a fair shot at participating in markets that help make sense of the world. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets. I've been trading on platforms like Kalshi for a while now, and I believe these markets offer real value to people like me and to society as a whole.
Prediction markets aren't just a hobby for me; they provide information I can't get anywhere else. I've seen firsthand how their forecasts on elections and public events are often more accurate than polls or talking heads on TV. That kind of insight helps me make better decisions, whether it's about my own finances or just understanding what's happening in the country. I think this benefits everyone, not just traders. Plus, letting regular folks like me participate feels fair. If only big institutions can play, they hoard all the good data. Opening these markets up makes the prices sharper and more reflective of reality.
I also want to push back on the idea that event contracts are gambling. Trading on Kalshi takes research and judgment, just like when I decide to invest in a stock or mutual fund. It's about analyzing real-world events, not rolling dice. These contracts have legitimate economic purposes, like helping people hedge risks or discover prices for uncertain outcomes. Calling this gaming feels like a stretch, and I'm concerned that over-restricting or banning these markets would just drive activity to unregulated offshore platforms. That seems way riskier than keeping them under the CFTC's oversight.
On the topic of risks, I know there are concerns about manipulation or insider trading. But aren't those already illegal? The CFTC has strong tools to go after bad actors in other markets, and I trust those can be applied here too. Shutting down or overly restricting prediction markets to stop a few cheaters feels like punishing the rest of us who play by the rules. I also believe the US should be a leader in financial innovation. If we clamp down too hard, other countries will step in and take the lead, and we'll lose out.
I'm particularly drawn to Questions 7 and 15 in your notice, about balancing innovation with public interest and defining what counts as gaming. I urge you to focus on proportionate regulation that targets specific risks rather than broad bans. Let's keep these markets accessible and safe without throwing out their benefits.
Thank you for considering my perspective. I strongly support well-regulated prediction markets and ask that the CFTC avoid over-restricting or banning them. Let's keep this space open for regular people like me while addressing real concerns with smart, targeted rules.
Sincerely,
Jacob Benish
