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Comment for Proposed Rule 91 FR 12516

  • From: Dylan Nightingale
    Organization(s):

    Comment No: 116621
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Dylan Nightingale, and I'm a student from New Jersey. I'm writing to share my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide unique value, and I believe the CFTC should regulate them in a way that encourages innovation while addressing legitimate concerns.


    Prediction markets arent just a hobby for me; theyre a tool for understanding the world. Ive used platforms like Kalshi to trade on election outcomes and other public events, and Im consistently impressed by how much more accurate their forecasts are compared to traditional polls or pundit opinions. As a student, I rely on accurate information to make sense of complex issues, and these markets cut through the noise. They aggregate what people really think, based on where theyre willing to put their money. This isnt just useful for traders like me. Its valuable for the public, media, and even policymakers who need reliable data to make decisions. I think this ties directly to your questions on price discovery and public interest in Topic Area B, especially Question 7 about balancing innovation with consumer protection.


    I also strongly believe that regulated markets are the way to go. Platforms like Kalshi, operating under CFTC oversight, provide transparency and safety that you simply dont get with unregulated offshore sites. If the CFTC over-restricts or bans certain types of event contracts, people like me wont stop trading; well just get pushed to less safe venues where theres no oversight at all. That seems counterproductive. On this point, Id urge you to consider Question 14 in Topic Area B about the broader impacts of regulation. Keeping activity in regulated spaces protects consumers far better than driving it underground.


    Finally, I think the U.S. has a chance to lead in financial innovation. Prediction markets are a cutting-edge tool, and if we clamp down too hard, other countries will step in and take the lead. I dont want to see that happen. We should be setting the standard for how these markets operate, not ceding ground. This connects to your broader questions in Topic Area F, like Question 33, about how regulation shapes market development.


    I understand there are concerns about manipulation or insider trading, but the CFTC already has tools to address those issues. Banning or over-restricting prediction markets punishes everyone for the actions of a few bad actors. Instead, I urge you to craft proportionate rules that protect consumers while allowing these markets to thrive. Thank you for considering my perspective.


    Sincerely,

    Dylan Nightingale

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