Comment Text:
Dear Chairman and Commissioners,
My name is Robert Lena, and I'm a healthcare professional from North Carolina. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm relatively new to prediction markets, but I strongly support their existence under thoughtful, proportionate regulation by the CFTC. I believe they offer unique value to people like me and to society as a whole.
As someone working in healthcare, I see firsthand how public events and policy decisions, like elections or regulatory changes, can impact my field and personal finances. Prediction markets provide a way to access accurate, real-time forecasts on these events, often more reliable than polls or media speculation. They also offer a chance to hedge against financial risks tied to things like policy shifts that could affect my income or costs. Beyond that, I value the freedom to participate in legal, regulated markets as a way to engage with the world around me.
I want to emphasize a few points that matter to me. First, regulated platforms like Kalshi are far safer than unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, people will just turn to less safe venues outside U.S. oversight, which helps no one. Second, event contracts aren't gambling. They serve real economic purposes, like forecasting and hedging, much like other financial instruments. Classifying them as gaming feels like a misstep. Third, the U.S. should be a leader in financial innovation, not leave this space to other countries. We have the chance to set a global standard here.
I also appreciate the academic research showing how prediction markets aggregate information efficiently. That transparency benefits everyone, from individuals to policymakers. Addressing some of the CFTC's specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe the balance between innovation and consumer protection lies in regulation, not prohibition. And on Topic Area C regarding listed activities (Questions 15-22), I urge you not to treat these contracts as gaming but as tools for legitimate economic activity.
I understand concerns about manipulation or insider trading, but those issues are already illegal under existing laws. The CFTC has tools to tackle bad actors without broad bans that punish everyone else. Targeted rules make more sense than categorical restrictions.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Please don't ban or over-restrict them. Let regular folks like me participate in a safe, regulated environment that fosters innovation and transparency. Thank you for considering my input.
Sincerely,
Robert Lena
