Comment Text:
Dear Chairman and Commissioners,
My name is Gregory Tod, and I'm a trader in a firm with presence in Delaware. I've been actively trading on prediction markets like Kalshi for a while, and Im writing to support regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516).
These markets are valuable to individuals, to businesses, and society as a whole, and I urge you to regulate them proportionately, rather than imposing broad bans or overly restrictive rules.
Ive seen firsthand how prediction markets deliver forecasts that often beat polls and pundits, especially on elections and major public events. The wisdom in the aggregated price has a value I cant get elsewhere. This isnt just useful for me; it benefits everyone when better information is available
Im concerned about U.S. competitiveness in financial innovation. If we over-restrict or ban prediction markets, we risk pushing activity to unregulated offshore platforms, which are far less safe than regulated markets like Kalshi operating under CFTC oversight. The U.S. should be leading here, not ceding ground to other countries. Banning or stifling these markets stands to drive innovation and capital elsewhere.
Regarding some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe the benefits of innovation, price discovery, and risk management clearly outweigh the risks if regulation is done right. On Topic Area E about inside information (Questions 29-32), I think informed trading actually improves price discovery and benefits all participants by making prices more accurate. The CFTC already has strong tools to tackle manipulation and insider trading in other markets. These can be adapted here without resorting to broad prohibitions.
There are valid concerns about potential abuse, but the answer isnt to shut down the entire market. Rather: target risks with specific, proportionate rules. The CFTC has the authority yo handle bad actors without punishing honest actors.
I urge you to support the growth of prediction markets with sensible oversight that keeps the U.S. at the forefront of financial innovation.
Yours sincerely,
Gregory Tod
