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Comment for Proposed Rule 91 FR 12516

  • From: Sam Winner
    Organization(s):

    Comment No: 116665
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Sam Winner, and I'm a trader and investor based in Minnesota. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the development of well-regulated prediction markets in the United States, and I want to share why I think this matters, both for me personally and for the broader public.


    As a trader, I've seen firsthand how prediction markets provide information you can't get anywhere else. Their forecasts on elections and public events consistently beat polls and pundits. I rely on these prices to make informed decisions, not just for trading but for understanding the world. This isn't just useful for me; it's valuable for everyone, from policymakers to everyday folks trying to make sense of complex events. The data transparency and academic research behind prediction markets, showing how they aggregate information efficiently, only reinforces their importance.


    I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, give me confidence that there are safeguards in place. That's a far cry from unregulated offshore alternatives, which lack accountability. Banning or over-restricting prediction markets won't stop people from trading; it will just push activity to less safe venues. I've traded on offshore platforms before, and the difference in transparency and consumer protection is night and day. The US should be leading in financial innovation, not ceding ground to other countries by driving this activity out of reach of proper oversight.


    I'm not blind to the concerns about manipulation or insider trading, but I believe the answer lies in proportionate, targeted regulation, not broad bans. Informed trading actually improves price discovery, benefiting all participants. The CFTC already has tools to tackle bad actors, and those should be applied here without punishing everyone else. I think your questions 7 through 14 on balancing innovation with consumer protection, and questions 29 through 32 on inside information, get to the heart of this. Focus on enforcing existing laws and crafting specific rules for real risks, rather than categorical restrictions that stifle a useful market.


    Prediction markets aren't just a niche hobby for traders like me. They're a tool for better public decision-making and a way to democratize access to valuable information. I urge the CFTC to support their growth with thoughtful regulation that keeps them safe and accessible. Don't let overreach or bans push this innovative space offshore. Let's keep the US at the forefront.


    Thank you for considering my input.


    Sincerely,

    Sam Winner

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