Comment Text:
Dear Chairman and Commissioners,
My name is Kukea Emmsley, and I'm just an everyday citizen from Hawaii writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm new to prediction markets, but I strongly support their existence under fair and balanced regulation. I believe they offer real value to people like me, and I want to explain why I think the CFTC should regulate them thoughtfully instead of restricting or banning them.
Living in Hawaii, I often feel far removed from the big political and economic events that still impact my life, like national elections or federal policy changes. I've noticed that prediction markets often provide forecasts on these events that are way more accurate than what I hear from polls or pundits on TV. That kind of information helps me make sense of what's coming and plan accordingly, even if I'm not trading myself. I think this benefit matters to everyone, not just traders. Beyond that, I see how these markets could help people hedge real financial risks. For example, if I'm worried about how an election might affect taxes or regulations that hit my family's small business, a prediction market could let me offset some of that uncertainty. This isn't gambling to me; it's practical.
I'm also concerned about access and fairness. I believe regular folks like me should have the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, seem much safer than unregulated offshore sites. If the CFTC over-restricts or bans these markets, I worry that activity will just move to those less safe places where there's no protection at all. The U.S. should be leading the way in financial innovation, not letting other countries take over because we're too cautious. We have a chance to set the standard here.
On some of the specific questions in the ANPR, like those in Topic B about public interest (Questions 7-14), I think prediction markets clearly serve the public by improving price discovery and helping with risk management. On Topic C (Questions 15-22), I don't believe event contracts should be labeled as gaming. They have legitimate economic purposes, like hedging and forecasting, that set them apart. And on Topic E (Questions 29-32), I think informed trading actually helps make prices more accurate, benefiting everyone. As for manipulation or insider trading, I understand the concern, but the CFTC already has strong tools to tackle those issues. Let's not punish the whole market for the actions of a few bad actors.
I urge you to support proportionate regulation that targets specific risks without broad bans. Keep prediction markets accessible, safe, and innovative under CFTC oversight. Thank you for considering my perspective.
Sincerely,
Kukea Emmsley
