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Comment for Proposed Rule 91 FR 12516

  • From: Nick Sonnenberg
    Organization(s):

    Comment No: 116687
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Nick Sonnenberg, and Im a trader and investor based in New York. Im writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). Ive been actively trading on platforms like Kalshi and Polymarket for a while now, and Ive seen firsthand the unique value these markets provide, both to me personally and to society at large.


    As a trader, I rely on prediction markets for information that I simply cant get anywhere else. Their forecasts on elections and other public events consistently outperform polls and pundits. Ive used these insights to make better decisions, not just in trading but in understanding the world around me. This isnt just about profit. Its about having access to aggregated, real-time data that benefits everyone, from individual investors like me to businesses and even policymakers. I also use these markets to hedge personal financial risks tied to events like policy changes or economic shifts, which directly impact my investments and planning.


    Im particularly concerned about the idea of over-restricting or banning these markets. Ive traded on both regulated platforms like Kalshi, under CFTC oversight, and unregulated offshore ones like Polymarket. The difference in safety and transparency is night and day. Pushing activity offshore by over-regulating here in the US would be a huge mistake. It would hurt consumer protection, not help it. Plus, the US should be leading in financial innovation, not handing that edge to other countries. We have the talent and infrastructure to set the global standard.


    I also want to address some of the specific questions in the ANPR. On Questions 7-14 regarding public interest, I believe prediction markets serve a clear public good through price discovery and risk management. Theyre not gambling. They require research and judgment, much like trading stocks or futures. On Questions 29-32 about inside information, I think informed trading actually improves price accuracy, benefiting all participants. And lets be clear, the CFTC already has strong tools to combat manipulation and insider trading in other derivatives markets. Those can be adapted here without resorting to broad bans.


    I urge the CFTC to craft rules that support well-regulated prediction markets while addressing specific risks with targeted measures. Dont punish the many for the actions of a few bad actors, and dont drive innovation and activity offshore. These markets provide accurate forecasting, hedging opportunities, and better information for everyone. Lets keep them accessible and safe under US oversight.


    Thank you for considering my input.


    Sincerely,

    Nick Sonnenberg

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