Comment Text:
Dear Chairman and Commissioners,
My name is James Odriscoll, and I'm a trader and investor based in Pennsylvania. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the development of well-regulated prediction markets in the United States, and I want to share why I think this matters, both for me personally and for the broader public.
As a trader, I've seen firsthand how prediction markets provide unique insights that you just can't get from polls or pundits. Whether it's forecasting election outcomes or other major public events, the prices on these platforms often cut through the noise and give a clearer picture of what's likely to happen. This isn't just helpful for those of us trading; its valuable information for everyone, from journalists to policymakers. I also believe that allowing regular people like me to participate in these markets makes the system fairer. If only big institutions can trade, they hoard all the good data. Opening it up democratizes access and improves price discovery, which benefits society as a whole.
I want to stress that this isn't gambling. Trading on prediction markets takes research and judgment, much like trading stocks or commodities. I spend hours reading up on events, analyzing trends, and making informed decisions. Labeling this as "gaming" would be like calling any investment speculative gambling, which doesn't hold up. These markets also serve real economic purposes, like hedging against uncertainty in politics or policy that can impact my investments.
One of my biggest concerns, though, is safety and consumer protection. I've traded on both regulated platforms like Kalshi, which operate under CFTC oversight, and unregulated offshore ones like Polymarket. The difference is night and day. Regulated markets have clear rules, transparency, and accountability. Offshore platforms? You're rolling the dice on whether you'll even get your money back. Banning or over-restricting prediction markets here in the US won't stop trading; it'll just push people like me to riskier, less safe venues. Regulation, not prohibition, is the answer.
I'm also worried about US competitiveness. If we stifle prediction markets with heavy-handed rules, we're handing the lead in financial innovation to other countries. We should be setting the standard, not playing catch-up.
Regarding some of the specific questions in the ANPR, Id like to address Question 7 on balancing innovation and consumer protection. I think the CFTC can strike that balance by focusing on strong oversight of domestic platforms rather than broad bans. And on Question 15, about defining gaming versus legitimate markets, I urge you to recognize that event contracts have real economic value and shouldn't be lumped in with gambling.
I respectfully ask the CFTC to support proportionate regulation of prediction markets. Please don't impose overly restrictive rules or outright bans that punish legitimate traders and drive activity offshore. Focus on using the tools you already have to prevent manipulation and insider trading, and let these markets grow under fair oversight.
Thank you for considering my input.
Sincerely,
James Odriscoll
