Comment Text:
Dear Chairman and Commissioners,
My name is Ryan Miller, and I'm a finance student based in Georgia. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone studying the financial industry, I've become fascinated by prediction markets and their potential, and I actively trade on platforms like Kalshi. I believe these markets serve an important purpose and deserve thoughtful, proportionate regulation rather than heavy-handed restrictions.
I first got into prediction markets through Kalshi because it felt accessible and safe, unlike some of the sketchy offshore platforms I've read about. As a student, I don't have a huge budget, but being able to participate in a regulated market lets me learn about real-world finance while hedging small personal risks, like election outcomes that could impact student loan policies or economic data releases that affect my part-time job's hours. This isn't gambling to me. It takes research and critical thinking, much like trading stocks or commodities. Classifying event contracts as gaming, as discussed in Questions 15-22 of the ANPR, overlooks their legitimate economic value for price discovery and risk management.
I'm also concerned about U.S. competitiveness. If we over-regulate or ban prediction markets, we risk pushing innovation and talent to other countries. The U.S. should be a leader in financial technology, not a follower. Regulated platforms like Kalshi keep activity onshore, under CFTC oversight, which is far better for consumer protection than driving users to unregulated offshore sites. This ties into Questions 7-14 on public interest, where I think the balance should favor innovation with sensible safeguards.
On the topic of manipulation and insider trading, raised in Questions 29-32, I believe the CFTC already has strong tools to address these issues. Informed trading often improves price accuracy, which benefits everyone, not just traders. Banning markets to stop a few bad actors punishes students like me who use these tools responsibly. Plus, the forecasting data from prediction markets, often more accurate than polls, helps inform public decision-making on elections and events. I've seen this firsthand in my studies, where academic research consistently shows markets aggregating information better than traditional methods.
I urge you to focus on targeted rules that address specific risks, rather than broad categorical bans. Questions 23-28 on procedural aspects are relevant here, and I support a case-by-case approach to public interest determinations, ensuring legitimate markets aren't unfairly restricted. Let's keep prediction markets accessible to regular people while maintaining strong oversight.
Thank you for considering my input. I strongly support proportionate regulation of prediction markets to foster innovation, protect consumers, and maintain U.S. leadership in finance.
Sincerely,
Ryan Miller
