Comment Text:
Dear Chairman and Commissioners,
My name is Julian Pryor, and I'm a student from California. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I want to express my strong support for well-regulated prediction markets. I believe they provide unique value to society and to people like me who are trying to understand the world through data and analysis.
I've been fascinated by how prediction markets aggregate information in ways that polls and pundits often can't match. As a student, I rely on accurate forecasts for elections and major public events to inform my studies and civic engagement. I've seen firsthand how platforms like Kalshi often predict outcomes with more precision than traditional surveys. This isn't just useful for traders; it helps everyone, from journalists to policymakers, make sense of complex issues. I think this kind of price discovery and better information flow is a public good, and I hope the CFTC recognizes that in its approach to Questions 7 and 8 about balancing innovation with consumer protection.
I also value the freedom to participate in legal, regulated markets. Trading on prediction markets isn't gambling to me. It takes research and critical thinking, much like any other investment. Platforms like Kalshi, which operate under CFTC oversight, are transparent and safe compared to unregulated offshore sites. If the CFTC over-restricts or bans these markets, I worry that activity will just move to less secure venues where theres no accountability. I'd urge the Commission to consider this when addressing Questions 15 through 22 on defining legitimate market activities and avoiding overly broad restrictions.
Another concern I have is maintaining U.S. competitiveness in financial innovation. We should be leading the way on new tools like prediction markets, not ceding ground to other countries. Banning or stifling these platforms would push innovation elsewhere, and I think that's a mistake. On top of that, I believe the CFTC already has strong tools to handle risks like manipulation or insider trading. There's no need for heavy-handed bans when existing laws and enforcement powers can address bad actors. I hope the Commission looks at Questions 29 through 32 on insider information with this in mind, focusing on enforcement rather than prohibition.
Prediction markets matter to me as a student because they democratize access to information and give people like me a stake in understanding real-world events. I respectfully ask the CFTC to support proportionate regulation that allows these markets to thrive while addressing specific risks with targeted rules. Please don't ban or over-restrict them. Thank you for considering my perspective.
Sincerely,
Julian Pryor
