Comment Text:
Dear Chairman and Commissioners,
My name is Tim Cunningham, and I'm an everyday citizen from Iowa writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I strongly support their regulation in a fair and balanced way that allows people like me to participate while addressing legitimate risks.
I believe prediction markets are valuable for a few key reasons. First, they provide better information than polls or pundits. I've seen firsthand how the prices on these platforms often predict outcomes more accurately than what I hear on the news or read in opinion pieces. That kind of insight helps not just traders, but anyone who wants to understand what's likely to happen, whether it's an election or an economic shift. Second, these markets let regular folks like me hedge personal financial risks. For instance, Ive considered using them to offset uncertainties around policies that could impact my taxes or costs as a homeowner. It's not gambling, it's a practical tool, much like buying insurance or investing in stocks.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore sites. If the CFTC bans or over-restricts prediction markets, I worry it will just push activity to those less safe venues where there's no accountability. The US should be a leader in financial innovation, not cede that space to other countries. Keeping these markets here, under proper rules, benefits everyone.
On the concerns about manipulation or insider trading, I get why that's a worry. But the CFTC already has strong tools to tackle those issues, just as it does for other derivatives. Banning entire categories of contracts or over-regulating them punishes honest participants like me instead of targeting bad actors. I think informed trading actually helps price discovery, as noted in questions 29-31 of the ANPR. When knowledgeable people trade, it makes the market's predictions sharper, which benefits us all. The focus should be on proportionate, targeted rules, not broad restrictions, as discussed in questions 7-14 around public interest and innovation.
I'm just a regular Iowan who sees prediction markets as a useful tool for information and financial planning. I urge the CFTC to regulate these markets in a way that protects consumers without stifling access or innovation. Let's keep them legal, safe, and open to everyday people.
Sincerely,
Tim Cunningham
