Comment Text:
Dear Chairman and Commissioners,
My name is Benjamin Mensah, and I'm a software engineer based in New Jersey. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi and Polymarket, I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to individuals like me, to businesses, and to society as a whole.
I got into prediction markets because, as a tech professional, Im always looking for data-driven insights. The forecasts these markets produce are often more accurate than polls or pundits. Ive seen this firsthand during election cycles, where platforms like Kalshi have helped me cut through the noise and get a clearer picture of likely outcomes. This isnt just useful for traders; its valuable for anyone making decisions, from journalists to policymakers. Beyond forecasting, Ive used these markets to hedge personal financial risks. For instance, Ive placed trades to offset potential impacts of policy changes on my freelance tech consulting income. This kind of hedging isnt gambling. Its a practical tool, much like trading stocks or commodities, grounded in research and real-world judgment.
Im also concerned about the idea of classifying event contracts as gaming, as discussed in Questions 15-22 of the ANPR. These contracts serve legitimate economic purposes, like price discovery and risk management. Calling them gambling ignores the skill and analysis involved. Plus, informed trading, as touched on in Questions 29-32, actually improves price discovery. It benefits everyone by making market signals clearer, not just those trading.
I understand there are risks, like manipulation or insider trading. But the CFTC already has strong tools to address these issues in other derivatives markets. I believe those can be adapted here without resorting to broad bans or over-restrictions. Banning or heavily limiting prediction markets, as some might suggest, would likely push activity to unregulated offshore platforms. Ive seen what those look like, and theyre far less safe than a regulated venue like Kalshi. Regulation, not prohibition, is the way to protect consumers.
On a broader level, I think the US has a chance to lead in financial innovation, a topic raised in Questions 7-14 about public interest. If we over-regulate or ban these markets, we risk ceding ground to other countries. As someone in tech, I know how fast innovation moves. Lets not fall behind. I urge you to focus on proportionate, targeted rules that address specific risks rather than sweeping categorical restrictions.
Thank you for considering my input. I strongly encourage the CFTC to support the growth of regulated prediction markets with fair, balanced regulations that protect participants while preserving access and innovation.
Sincerely,
Benjamin Mensah
