Comment Text:
Dear Chairman and Commissioners,
My name is Aaron Moore, and I'm a software engineer based in Colorado. I've been working in tech for over a decade, and in my spare time, I actively trade on prediction markets like Kalshi. I'm writing to support the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to individuals like me, businesses, and society as a whole, and I urge the CFTC to regulate them in a way that protects consumers while preserving innovation.
As someone who crunches data and builds systems for a living, I'm fascinated by how prediction markets aggregate information. I've seen firsthand how their forecasts on elections and public events often outperform polls or pundits. Last year, I used Kalshi to track election probabilities, and the market's predictions were far closer to the final outcome than any news outlet I followed. This isn't just a game for traders; it's valuable information that helps people make better decisions. I think this ties directly to Questions 7 and 8 in the ANPR about public interest and price discovery. These markets aren't just useful for me; they benefit everyone by making hard-to-find insights accessible.
I also want to stress that event contracts aren't gambling. I put real research and judgment into my trades, just like I would with stocks or other investments. For instance, I've used Kalshi to hedge personal risks, like potential policy changes that could affect tech regulations and, by extension, my job stability. This is a legitimate economic tool, not a slot machine, and I hope the CFTC considers this when defining "gaming" under Questions 15 and 16. Plus, as a regular person, I value the freedom to participate in legal, regulated markets. If only big institutions can trade, the best information stays locked away with them.
I'm also worried about what happens if regulation goes too far. Banning or over-restricting these markets would push activity to unregulated offshore platforms, which are far less safe. I've looked at some of those sites, and there's no consumer protection at all. Regulated platforms like Kalshi, under CFTC oversight, are the better option. This speaks to Questions 23 and 24 on public interest determinations. Let's keep this activity in a transparent, accountable space.
Finally, I believe the US should lead in financial innovation. As a tech worker, I know how fast the world moves. If we stifle prediction markets here, other countries will take the lead. And let's not forget the academic research, like studies by economists such as Justin Wolfers, showing how these markets improve information transparency. Informed trading isn't a bug; it's a feature that makes prices more accurate for everyone, as raised in Questions 29 and 30 on inside information.
I ask the CFTC to support proportionate, targeted rules for prediction markets. Address specific risks like manipulation with the tools you already have, rather than broad bans. Don't shut down a valuable tool because of a few potential bad actors. Thank you for considering my input.
Sincerely,
Aaron Moore
