Comment Text:
Dear Chairman and Commissioners,
My name is Christopher Ashmore, and I'm a trader and investor based in Hawaii. I've been active in various financial markets for years, and I've used prediction markets a few times to gain insights and hedge against uncertainties that impact my investments. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets and to urge the CFTC to adopt a balanced, proportionate approach to regulation.
As someone who values the freedom to participate in legal, regulated markets, I believe prediction markets offer unique benefits that shouldn't be stifled by overly restrictive rules. Platforms like Kalshi, which operate under CFTC oversight as designated contract markets, provide a safe and transparent environment for trading event contracts. I've found these markets helpful for understanding probabilities on economic and political events that affect my portfolio, something polls or news often get wrong. They're not just a niche tool for a few; they aggregate information in a way that's useful to everyone.
But here's my concern. If the CFTC bans or over-restricts these markets, activity won't just stop. It'll move to unregulated offshore platforms where theres no oversight, no consumer protection, and no accountability. I've seen this happen in other areas of trading. Pushing legitimate activity into the shadows is a mistake when regulated options like Kalshi already exist. I'd rather trade in a market where the CFTC can step in if something goes wrong.
I also want to push back on the idea that event contracts are just "gaming." That's not accurate. Trading on these platforms takes research and judgment, much like trading stocks or futures. They serve real economic purposes, like price discovery and hedging risks that impact my investments. Classifying them as gaming would be like calling all investing a gamble, and I hope the CFTC avoids that framing when addressing questions like 15 and 16 from the ANPR about defining legitimate markets.
Another point I feel strongly about is the need for the US to lead in financial innovation. We shouldn't cede this space to other countries by over-regulating. Prediction markets are a growing field, and if the US sets the standard with smart rules, we can shape how they're used globally. This ties into questions 7 and 8 from the ANPR about balancing innovation with consumer protection. I believe the answer is targeted regulation, not broad bans. Address specific risks like manipulation or insider trading with existing tools, as discussed in questions 29 through 32. Don't punish everyone by shutting down entire categories of contracts.
I'm just a trader trying to navigate an uncertain world, and prediction markets give me a way to do that. I ask the CFTC to support proportionate regulation that keeps these markets accessible, safe, and innovative. Don't let heavy-handed rules push us offshore or kill a useful tool.
Thank you for considering my input.
Sincerely,
Christopher Ashmore
