Comment Text:
Dear Chairman and Commissioners,
My name is Jon Moorhead, and I'm a trader and investor based in Florida. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support well-regulated prediction markets and want to share why I believe the CFTC should adopt proportionate rules rather than bans or heavy restrictions.
As a trader, Ive seen firsthand how prediction markets provide information you cant get anywhere else. Their forecasts on elections, economic data, and other events are often more accurate than polls or pundits. Thats not just useful for me when Im making trades; its valuable for society as a whole. These markets also let regular people like me hedge real risks. For instance, Ive used them to offset uncertainties around policy changes that could affect my investments. This isnt gambling. Its research and judgment, no different from trading stocks or commodities. Classifying event contracts as gaming undercuts their legitimate economic purpose, and I urge the CFTC to recognize this in response to Questions 15-22 on listed activities.
I also believe regulated markets are the way to go. Platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If the CFTC bans or over-restricts these markets, people like me will be forced to trade on less secure platforms with no protections. Thats a lose-lose. Addressing Questions 7-14 on public interest, I think the US has a chance to lead in financial innovation here. We shouldnt cede this space to other countries by overregulating. Instead, build on the robust tools the CFTC already has to tackle manipulation and insider trading. Theres no need for broad bans when targeted rules can address specific risks, as raised in Questions 1-6 on core principles and Questions 29-32 on inside information. Informed trading, by the way, often improves price discovery. That benefits everyone in the market, not just a few.
I get the concerns about potential abuse. Bad actors are always a risk in any market. But shutting down prediction markets to stop a few cheats is like closing the stock market over insider trading. It punishes the wrong people. The answer is enforcement of existing laws, not categorical restrictions. If these markets are banned, Ill have no choice but to turn to offshore platforms, and I know Im not alone in that. Lets keep this activity in the US, under proper oversight.
I ask the CFTC to support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules. Dont let heavy-handed restrictions push traders like me offshore. Thank you for considering my perspective.
Sincerely,
Jon Moorhead
