Comment Text:
Dear Chairman and Commissioners,
My name is Madeleine Hall, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the development of well-regulated prediction markets in the United States, and I want to share why I believe they are valuable and why over-restricting them would be a mistake.
As a trader, I've seen firsthand how prediction markets offer insights you just can't get from polls or pundits. I've used platforms like Kalshi to trade on election outcomes and other public events, and the forecasts there have consistently been more accurate than what I see on TV or read in the news. This isn't just useful for me as a trader; it's valuable for everyone, from journalists to policymakers, who can benefit from better information. I think of it as a public good, not something to be stifled.
I also want to push back on the idea that event contracts are gambling. Trading on these markets takes research, analysis, and real-world judgment, much like trading stocks or commodities. I spend hours reading up on political trends or economic indicators before making a trade. Classifying this as "gaming," as discussed in Questions 15-22 of the ANPR, ignores the legitimate economic purpose it serves, like price discovery and even hedging against uncertainty. It's not a game; it's a serious financial tool.
Another reason I'm passionate about this is the importance of freedom to participate in legal, regulated markets. Prediction markets let regular people like me have a stake in understanding and forecasting major events. If only big institutions can play, the best information stays locked up with them. Democratizing access makes prices more accurate and levels the playing field. Plus, regulated markets are safer than the alternative. If the U.S. clamps down too hard, activity will just move to unregulated offshore platforms, which helps no one.
Finally, I believe the U.S. should be a leader in financial innovation, not a follower. Other countries are embracing these markets, and if we over-regulate or ban them, as touched on in Questions 7-14 about public interest, we risk ceding ground to foreign competitors. We have the chance to set the global standard for how prediction markets should work, with proper oversight to prevent manipulation or insider trading, issues already addressed by existing CFTC powers.
I'm asking you to support proportionate regulation of prediction markets. Address specific risks with targeted rules, but don't ban or overly restrict them. Let's keep the U.S. at the forefront of innovation while protecting consumers through smart, balanced oversight.
Sincerely,
Madeleine Hall
