Comment Text:
Dear Chairman and Commissioners,
My name is Fionn Allen, and I'm a wealth manager based in Nevada. I work with clients every day to help them navigate investments and manage risks, and I've come to see prediction markets as a vital tool in that process. 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, accessible prediction markets. I believe they offer unique benefits to individuals, businesses, and the broader economy, and I urge the CFTC to craft rules that foster innovation without stifling this growing asset class.
As someone who actively trades on platforms like Kalshi, I've seen firsthand how prediction markets provide information you can't get elsewhere. Their forecasts on elections and public events often outpace polls or pundits in accuracy, which helps me advise clients on potential market impacts. More importantly, these markets let people hedge real risks. For instance, a business owner I work with used an event contract to offset uncertainty around a potential regulatory change that could have hit their bottom line. This isn't gambling; it's a legitimate financial strategy, much like trading futures or options. I worry that labeling event contracts as "gaming," as discussed in Questions 15-22 of the ANPR, ignores their economic purpose and could unfairly restrict access.
I also see prediction markets as key to personal financial freedom. They're a legal, regulated way for everyday people to participate in markets that big institutions already tap into. If we over-restrict or ban these markets, as some might suggest, we're not protecting anyone. We're just pushing activity to unregulated offshore platforms where there's no oversight. I'd rather see the CFTC build on its existing tools to prevent manipulation and insider trading, as mentioned in Questions 1-6 and 29-32, than limit a market that benefits so many.
On a bigger scale, the U.S. has a chance to lead in financial innovation. Prediction markets could become a major asset class, and I believe my income and my clients' portfolios will increasingly rely on access to them. If we limit these markets now, we risk ceding ground to other countries that embrace this technology. I think the CFTC should focus on proportionate regulation, not broad restrictions, as raised in Questions 7-14 about balancing innovation and consumer protection.
I'm not blind to the risks. Manipulation and insider trading are real concerns, but the CFTC already has the authority to tackle those issues. Shutting down prediction markets to stop a few bad actors feels like overkill. Let's regulate smartly instead.
I respectfully ask the CFTC to support the growth of prediction markets with rules that address specific risks without banning or overly restricting access. Let's keep the U.S. at the forefront of financial innovation.
Sincerely,
Fionn Allen
