Comment Text:
Dear Chairman and Commissioners,
My name is Roudkenson Deliard, and I'm a professional trader and investor based in Illinois. I've spent years navigating financial markets, analyzing data, and making informed decisions to grow my portfolio. While I'm relatively new to prediction markets, I strongly support their development under fair and proportionate regulation. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516, to share my perspective as someone who values both market freedom and the importance of a well-regulated financial system.
As a trader, I believe in the right to participate in legal, regulated markets. Prediction markets offer a unique opportunity for people like me to engage with events that impact our lives and livelihoods, whether it's an election outcome affecting tax policy or a Federal Reserve decision influencing interest rates. These markets aren't just a novelty; they provide valuable information through price discovery that benefits not only participants but also the broader public. I've seen how informed trading, even by those with specialized knowledge, can sharpen the accuracy of these prices. In response to your questions 29-32 on inside information, I argue that informed trading often improves market efficiency rather than harms it, as long as existing laws against insider trading are enforced.
I also worry about what happens if the U.S. over-restricts or bans these markets. Platforms like Kalshi, operating as a CFTC-registered Designated Contract Market, offer a safe, transparent environment for trading event contracts. Compare that to unregulated offshore platforms where there's little oversight and far greater risks of fraud or manipulation. If we push prediction markets out of the U.S., we drive activity to these less safe venues. That's not protecting consumers; it's putting them at risk. On a related note, addressing your questions 7-14 about public interest, I believe the U.S. must lead in financial innovation. If we stifle prediction markets here, other countries will step in, and we'll lose our edge as a global leader in finance. We can't afford to fall behind.
I understand there are concerns about manipulation or misuse in prediction markets. But the CFTC already has powerful tools to combat fraud and insider trading in other derivatives markets. Use those tools here instead of broad prohibitions that punish legitimate participants like me. I'm asking you to craft regulations that target specific risks without shutting down an entire industry.
Thank you for considering my input. I urge the CFTC to support the growth of prediction markets through balanced, proportionate rules that keep markets safe and accessible while positioning the U.S. as a leader in financial innovation.
Sincerely,
Roudkenson Deliard
