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Comment for Proposed Rule 91 FR 12516

  • From: Tom Kline
    Organization(s):

    Comment No: 116336
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Tom Kline, and I'm a trader and investor based in Iowa. I've been in the markets for years, mostly focusing on stocks and commodities, but I've also used prediction markets a few times to get a read on events that impact my financial decisions. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) because I strongly support the freedom to participate in legal, regulated markets like these, and I want to share my perspective.


    Prediction markets have been a valuable tool for me. They often produce forecasts that are way more accurate than polls or pundits on TV. I've seen this firsthand when I used a platform to gauge the likelihood of certain economic policies passing. That information helped me make better decisions about my investments. It's not just useful for me, though. These markets aggregate what lots of people know and think, creating insights that benefit everyone, from regular folks like me to policymakers. I believe the CFTC should recognize this value, especially when considering Questions 7 and 8 about public interest and price discovery.


    I also want to stress that regulated markets, like Kalshi, are far safer than the unregulated offshore platforms out there. I've looked at some of those offshore sites, and theyre sketchy at best. No oversight, no accountability. If the CFTC over-restricts or bans prediction markets here, people arent going to stop trading. Theyll just go to those unsafe platforms instead, and thats worse for everyone. Regulation done right keeps activity on U.S. soil where it can be monitored. This ties directly to Question 14 about balancing innovation and consumer protection. I think the answer is clear: support regulated markets, dont push people offshore.


    Another concern Ive heard is about manipulation or insider trading. I get why thats a worry, but the CFTC already has strong tools to handle this in other markets. Ive seen how you crack down on bad actors in commodities and futures. Those same powers can apply here. Theres no need for broad bans when targeted enforcement works better. This relates to Questions 29 and 30 on insider information. Yes, its a risk, but its one youre already equipped to manage without shutting everything down.


    Im not saying there shouldnt be rules. I just think they should be proportionate. Focus on specific risks instead of blanket restrictions on whole categories of contracts. Banning or over-restricting these markets would hurt regular traders like me who use them responsibly. So, Im asking the CFTC to support well-regulated prediction markets with targeted, fair rules that keep innovation alive while protecting participants.


    Thank you for considering my input.


    Sincerely,

    Tom Kline

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