Comment Text:
Dear Chairman and Commissioners,
My name is Andrew Kutzler, and I'm just an everyday citizen from Pennsylvania writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I feel strongly that these markets should be supported with fair, proportionate regulation rather than heavy-handed restrictions.
I believe prediction markets are valuable, not just for me but for society as a whole. They're not gambling, no matter what some might say. When I trade on an event contract, I'm putting in time to research and think through real-world issues, whether it's an election outcome or an economic indicator. It's no different from the kind of judgment I use when investing in stocks. These markets help me hedge against uncertainties that affect my life, like policy changes that could impact my taxes or costs. Plus, the prices often give insights you can't find in polls or news. That's useful for everyone, not just traders like me.
What I really care about is having the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore sites. If you over-restrict or ban these markets, people aren't going to stop trading; they'll just move to less safe venues where there's no protection. I've seen how Kalshi has clear rules and transparency. That's the kind of environment I want to trade in, not some sketchy offshore platform.
I also think the US should be a leader in financial innovation. We shouldn't let other countries take the lead on something like this. Prediction markets are a new way to aggregate information and manage risk. If we clamp down too hard, we'll lose out on the benefits and push innovation elsewhere. In response to some of your questions, like those in Topic Area B on public interest (Questions 7-14), I'd argue that innovation and consumer protection can go hand in hand with smart rules, not bans. And on Topic Area C about listed activities (Questions 15-22), I strongly believe event contracts shouldn't be classified as gaming. They serve real economic purposes, like hedging and price discovery.
I'm not blind to the risks. I know there are concerns about manipulation or insider trading. But the answer isn't to shut everything down. Broad categorical bans punish regular folks like me who are just trying to engage with the world in a new way. Instead, focus on targeted regulations to address specific issues, as you ask about in Topic Area D (Questions 23-28). Use the tools you already have to go after bad actors without throwing out the whole market.
I urge you to support proportionate regulation of prediction markets. Keep them legal and accessible under fair oversight, and don't let over-restriction push activity into unsafe corners of the internet. Thank you for considering my perspective.
Sincerely,
Andrew Kutzler
