Comment Text:
Dear Chairman and Commissioners,
My name is Phillip Stuben, and I'm a trader and investor based in Florida. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing to support well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to people like me, to businesses, and to society as a whole, and I urge you to craft rules that allow them to thrive under fair oversight.
As someone who trades regularly, I've seen firsthand how prediction markets help me hedge real financial risks. For instance, Ive used these platforms to offset potential losses tied to election outcomes that could impact my investments or tax planning. It's not just about making a bet; it's about protecting myself from uncertainty in a way that traditional markets don't always allow. I know small businesses that do the same, hedging against policy changes or economic shifts. This isn't gambling. It takes research and judgment, just like trading stocks or commodities. Classifying event contracts as "gaming" ignores their legitimate economic purpose, and I hope the CFTC avoids that misstep when addressing questions like 15 and 16 in your ANPR about defining gaming versus legitimate markets.
Beyond personal use, Im convinced that prediction markets offer better information for everyone. The prices on these platforms often predict election results or public events more accurately than polls or pundits. Thats because informed trading improves price discovery, benefiting not just traders but anyone who looks at the data, from journalists to policymakers. When regular people like me can participate in these markets, the information gets even sharper. Locking out everyday traders would just concentrate that insight with big institutions, which seems unfair. I think this ties directly to your questions 7 and 8 on balancing innovation with consumer protection and the public interest. The answer is clear: regulated access for all supports better decision-making.
I also worry that over-restricting these markets could hurt US competitiveness in financial innovation. If we push this activity offshore to unregulated platforms, we lose control and put traders at risk. Keeping prediction markets here under CFTC oversight is the safer, smarter path. And lets not forget that insider trading or manipulation are already illegal. The CFTC has the tools to handle bad actors without banning entire markets. Shutting down prediction markets to stop a few cheaters would punish the rest of us who trade honestly.
Im asking you to support proportionate regulation that addresses specific risks without over-restricting or banning event contracts. Lets keep these markets open to individuals and businesses who use them responsibly. Thank you for considering my perspective.
Sincerely,
Phillip Stuben
