Comment Text:
Dear Chairman and Commissioners,
My name is Casey Richmond, and I'm a policy professional from South Carolina. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I believe they serve a valuable purpose when properly regulated. I want to share my perspective on why the CFTC should support well-regulated prediction markets rather than overly restricting or banning them.
As someone who works in policy, I see firsthand how important access to accurate information is for decision-making, both for individuals and for society at large. Prediction markets offer unique insights that often outpace polls or expert opinions. I've personally found them helpful for gauging public sentiment on key issues, and I think allowing regular people like me to participate in these markets is a net positive. It democratizes access to information and lets everyday citizens have a stake in understanding major events. But I also recognize the need for oversight to protect consumers, which is why I strongly support regulation over prohibition.
One of my biggest concerns is that heavy-handed restrictions or outright bans would push activity to unregulated offshore platforms. I've looked at markets like Kalshi, which operate under CFTC oversight, and I feel much safer participating there than on some foreign site with no accountability. Regulation ensures transparency and fairness, while bans just drive people to riskier alternatives. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. I believe these can be applied to prediction markets without reinventing the wheel. There's no need to punish everyone by shutting down legitimate markets when the focus should be on enforcing existing laws against bad actors.
I also want to address the idea of informed trading, which relates to questions 29 through 32 in your ANPR. I think traders with good information actually improve price discovery, which benefits everyone, not just those trading. Banning or over-restricting markets because of potential insider trading risks throwing out a valuable tool. The laws already in place, like those barring federal employees from trading on nonpublic info, are a better way to handle this than broad prohibitions.
I'm asking the CFTC to take a balanced approach. Craft regulations that address specific risks like manipulation or consumer harm, but don't block ordinary people from participating in legal, regulated prediction markets. Let's keep these markets safe and accessible under your oversight, not pushed into the shadows offshore. Thank you for considering my input.
Sincerely,
Casey Richmond
