Comment Text:
Dear Chairman and Commissioners,
My name is Justin Ford, and I'm a trader and investor based in Georgia. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the development of well-regulated prediction markets in the United States, and I want to share why these markets are valuable to me and why the CFTC should regulate them proportionately, not ban or overly restrict them.
As a trader, I rely on accurate information to make decisions. Prediction markets consistently provide forecasts on elections and public events that beat out polls and pundits. I've seen this firsthand on Kalshi, where the aggregated wisdom of many traders often paints a clearer picture than any news outlet. This isn't just useful for me; it's valuable for the public, policymakers, and anyone who needs reliable data to make decisions. Beyond forecasting, these markets let me hedge real financial risks. Whether it's an election outcome that could impact my taxes or a policy change that might hit my investments, trading on event contracts helps me manage uncertainty in a way traditional markets often can't.
I also believe that regulated platforms like Kalshi are far safer than the unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, people like me won't stop trading; we'll just be pushed to less transparent, riskier venues. That hurts consumer protection, not helps it. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. I trust those can be adapted here without resorting to broad bans. Informed trading, after all, improves price discovery and benefits everyone in the market, not just the traders.
Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets serve a clear public good through better information and risk management. They aren't gambling; they have legitimate economic purposes, as your questions in Topic Area C (Questions 15-22) explore. Classifying event contracts as "gaming" would be a mistake when they help people like me hedge real risks. And on Topic Area E (Questions 29-32), I think the risk of insider trading is overblown since laws already prohibit it, and the CFTC can enforce those rules without shutting down entire markets.
The U.S. should be a leader in financial innovation, not cede ground to other countries. I urge you to adopt targeted, proportionate regulations that address specific risks rather than imposing categorical restrictions. Prediction markets are a powerful tool for forecasting, hedging, and democratizing information. Let's keep them accessible and safe under CFTC oversight.
Thank you for considering my input.
Sincerely,
Justin Ford
