Comment Text:
Dear Chairman and Commissioners,
My name is Henry Persoon, and I'm a trader and investor based in Florida. I've been involved in various financial markets for years, and I've used prediction markets a few times to gain insights and manage risks. 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 prediction markets in the United States.
As someone who values the freedom to participate in legal, regulated financial markets, I believe prediction markets offer unique benefits that shouldn't be stifled by overly restrictive rules. I've found these platforms useful for getting information that I can't find anywhere else. The prices often reflect a clearer picture of what's likely to happen than polls or news commentary. Beyond that, they let regular people like me have a stake in understanding and anticipating real-world events, whether it's an election outcome or an economic policy change. This isn't gambling, it's a form of research and judgment, much like trading stocks or commodities.
What concerns me most is the idea of pushing this activity out of regulated spaces. I've used platforms like Kalshi, which operate under CFTC oversight, and I feel much safer knowing there's accountability and transparency. If the CFTC imposes bans or heavy restrictions, people won't just stop trading, they'll turn to unregulated offshore platforms where there are no protections. I've seen this happen in other areas of finance, and it never ends well for the average person. Regulated markets aren't perfect, but they're a lot better than the alternative.
I also want to address a concern I've heard about manipulation or insider trading. I get why this is a worry, but the CFTC already has tools to tackle bad actors. Laws against insider trading and market manipulation apply across the board, and shutting down entire markets to stop a few cheaters punishes honest participants like me. Let's focus on enforcing existing rules, not creating new barriers.
In response to some of the specific questions in the ANPR, particularly those in Topic B on Public Interest (Questions 7-14), I urge the CFTC to balance innovation with consumer protection by supporting regulated platforms over outright bans. And regarding Topic D on Procedural Aspects (Questions 23-28), I believe the CFTC should avoid broad categorical restrictions and instead evaluate contracts on a case-by-case basis to ensure legitimate markets aren't unfairly blocked.
I hope the CFTC will support proportionate regulation that allows prediction markets to thrive under clear, fair rules. Don't let heavy-handed restrictions drive this activity underground. Thank you for considering my perspective.
Sincerely,
Henry Persoon