Comment Text:
Dear Chairman and Commissioners,
My name is Zach Weisberg, 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 Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the idea of well-regulated prediction markets in the United States, and I want to share why I think theyre valuable, both for me personally and for society as a whole.
As a trader, Ive seen firsthand how prediction markets provide information you just cant get anywhere else. Whether its an election outcome or a major public event, the prices on these platforms have consistently been more accurate than polls or pundits. That kind of forecasting isnt just helpful for those of us trading; its useful for the public, media, and even policymakers who need reliable data to make decisions. Beyond that, Ive used these markets to hedge personal financial risks. For instance, trading on election outcomes has helped me offset potential impacts on my investments tied to policy changes. This isnt gambling. Its research, analysis, and real-world judgment, just like trading stocks or commodities.
I also believe that regulated markets, like Kalshi operating under CFTC oversight, are far safer than the alternative. If you ban or over-restrict these platforms, the activity doesnt disappear; it just moves offshore to unregulated sites like Polymarket. Ive traded on both, and I can tell you the difference in transparency and accountability is night and day. Pushing this activity out of the U.S. doesnt solve any problems; it just means less consumer protection and lost opportunities for American innovation. The U.S. should be leading in financial innovation, not handing that advantage to other countries.
Addressing some of the specific questions in the ANPR, Id like to touch on Question 7 about balancing innovation and consumer protection. I think regulation is the answer, not restriction. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets, as noted in Question 29 regarding inside information. These can be adapted to event contracts without banning entire categories. And on Question 15, about defining gaming versus legitimate markets, Id argue event contracts serve real economic purposes like hedging and price discovery. Theyre not slots or roulette; theyre tools for managing risk.
I get the concerns about manipulation or insider trading. Those are real issues. But the solution isnt shutting down prediction markets; its using the laws and powers the CFTC already has to go after bad actors. Dont punish the majority of honest traders for the actions of a few. I urge you to support proportionate regulation that allows prediction markets to thrive in a safe, transparent environment here in the U.S.
Thank you for considering my perspective.
Sincerely,
Zach Weisberg
