Comment Text:
Dear Chairman and Commissioners,
My name is Jeffrey Dier, and Im a trader and investor based in North Carolina. Ive been involved in various markets for years, and Ive used prediction markets a few times to gauge outcomes and manage risks. Im 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. I believe they offer unique value to individuals like me and to society as a whole, and I urge the CFTC to adopt proportionate, targeted regulations rather than broad restrictions.
Prediction markets are different from other sources of information. Ive seen firsthand how their forecasts often beat polls or pundits in accuracy, providing insights you cant get elsewhere. This isnt just useful for traders; it helps everyone make better decisions, from businesses to regular folks. I also value the ability to hedge personal or business risks through these markets. Whether its an election outcome affecting tax policies or a regulatory change impacting investments, event contracts let me manage uncertainty in a way traditional markets sometimes cant. And lets be clear, this isnt gambling. Researching and trading on these platforms requires the same kind of judgment I use in stocks or commodities. Classifying event contracts as gaming (as discussed in Questions 15-22) ignores their legitimate economic purpose, like price discovery and risk management.
Im also concerned about consumer protection, which is why I believe regulated markets like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore platforms. If we over-restrict or ban these markets, activity will just move to less safe venues. The US should lead in financial innovation, not cede ground to other countries. On that note, I think the CFTC already has strong tools to handle issues like manipulation and insider trading (relevant to Questions 29-32 on inside information). Informed trading actually improves price discovery, benefiting all participants. The answer isnt banning markets; its enforcing the rules youve got.
One concern I have is with data feeds in commodity and financial markets. Theres too much inconsistency with data pulled from multiple providers. Sometimes the contract month displayed doesnt match the official rules, and charts, like for WTI, can freeze and not update. Id urge the CFTC to consolidate data feeds directly from the CME to avoid confusion, ensuring clarity for traders like me.
I appreciate the CFTC seeking input on balancing innovation and protection (Questions 7-14 on public interest). I believe the best path is targeted regulation that addresses specific risks without punishing everyone. Please support the continued growth of prediction markets under a fair, proportionate framework.
Sincerely,
Jeffrey Dier