Comment Text:
Dear Chairman and Commissioners,
My name is David Jacobsen, and I'm a software engineer based in Washington state. I've been working in tech for over a decade, and in my personal time, I actively trade on prediction markets like Kalshi. I'm writing to express my strong support for well-regulated 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 and to society as a whole, and I urge the CFTC to adopt proportionate regulations rather than broad restrictions or bans.
As someone who geeks out on data and systems, Ive found prediction markets to be an incredible tool for understanding the world. The forecasts they produce on elections and public events are often more accurate than polls or pundits. Ive seen this firsthand on Kalshi, where the collective wisdom of traders cuts through noise and bias in a way traditional media cant. This isnt just useful for me as a trader; its valuable information for everyone, from journalists to policymakers. Its frustrating to think this resource could be stifled by overregulation.
I also want to push back on the idea that event contracts are gambling. Trading on these platforms isnt a game of chance. It takes research, analysis, and real-world judgment, much like any other investment. I use these markets to hedge risks tied to political or economic outcomes that could impact my life, like policy changes affecting tech or taxes. This serves a clear economic purpose, and I think its a mistake to lump it in with gaming, as some of the questions in the ANPR (like 15-22) seem to explore.
On the safety front, I strongly believe regulated platforms like Kalshi are far better than the alternative. If the CFTC over-restricts or bans these markets, people like me will just turn to unregulated offshore sites, which have no oversight and pose bigger risks. The US should be leading in financial innovation, not ceding ground to other countries. Addressing concerns raised in questions 7-14 about public interest, I think the CFTC already has solid tools to handle issues like manipulation and insider trading. Those are illegal already, and the focus should be on enforcing existing rules, not creating sweeping new bans that punish legitimate users.
Im particularly drawn to the discussion in questions 1-6 about core principles. I support targeted regulations to prevent manipulation or other abuses, but broad categorical restrictions would be a step backward. Proportionate rules that address specific risks make far more sense.
In short, prediction markets are a powerful, innovative tool that benefits people like me and society at large. I respectfully ask the CFTC to support their growth through fair, balanced regulation rather than heavy-handed limits or outright bans. Thank you for considering my perspective.
Sincerely,
David Jacobsen
