Comment Text:
Dear Chairman and Commissioners,
My name is Alexander Delaney, and I'm a student from Massachusetts writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times, and I believe they serve a valuable purpose when properly regulated. I'm particularly concerned with ensuring that regular people like me have the freedom to participate in legal, safe markets without being pushed toward riskier alternatives.
As a student, I've found prediction markets to be an interesting way to engage with real-world events while learning about economics and decision-making. I've placed a few small trades on platforms like Kalshi, and it felt like a practical way to test my understanding of current events, almost like a hands-on classroom exercise. I value having access to these markets because they let ordinary folks participate in a system that generates useful information, not just for traders but for society as a whole.
What worries me is the possibility of over-restricting or banning these markets altogether. If regulated platforms like Kalshi, which operate under CFTC oversight, are shut down or limited too heavily, people will just turn to unregulated offshore sites. I've seen those platforms advertised online, and they don't seem nearly as safe or transparent. There's no accountability there, no protections for users. Keeping prediction markets legal and regulated in the US ensures there's a safer space for participation, with rules to prevent fraud or manipulation. I'd much rather trade on a platform I know is watched by the CFTC than take my chances with some sketchy foreign site.
I also think regulation should be targeted and proportionate. Broad categorical bans on certain types of contracts, as discussed in some of your questions like numbers 15 through 22 on listed activities, seem like overkill. Instead of wiping out entire categories, why not focus on specific risks like insider trading or manipulation with tailored rules? The CFTC already has tools to address bad actors in other markets, and I believe those can be adapted here without punishing everyone else. I'm particularly interested in your thoughts on question 7 about balancing innovation and consumer protection, and I urge you to lean toward fostering innovation with smart, focused oversight.
In closing, I ask that the CFTC support the continued operation of regulated prediction markets with rules that address specific concerns rather than broad restrictions. Let's keep these markets accessible and safe for people like me who want to engage with them responsibly. Thank you for considering my perspective.
Sincerely,
Alexander Delaney
