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Comment for Proposed Rule 91 FR 12516

  • From: Kevin McCullough
    Organization(s):

    Comment No: 116712
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Kevin McCullough, and I'm a trader and investor based in Massachusetts. I'm writing to express my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've used prediction markets a few times myself, and I believe they offer unique value to individuals like me, as well as to the broader public.


    As someone who spends a lot of time analyzing markets and trends, I can say firsthand that prediction markets often provide better forecasts for elections and major public events than traditional polls or pundit opinions. I've seen this play out with my own trades, where the market's collective judgment cut through the noise and gave a clearer picture of likely outcomes. This kind of information isn't just helpful for traders; it's valuable for anyone making decisions, from journalists to policymakers. Its a tool for better public decision-making and price discovery, something we desperately need in uncertain times.


    Beyond forecasting, I also see prediction markets as a practical way to hedge real financial risks. For instance, as an investor, Im often exposed to policy changes or economic shifts tied to election results or regulatory decisions. Being able to hedge against those outcomes helps me manage uncertainty in my portfolio. I know businesses, too, could use these tools to protect against risks like sudden tariff changes or new regulations. This isnt gambling; its a legitimate way to stabilize finances in a volatile world.


    Im also concerned that if the U.S. over-restricts or bans these markets, well lose ground to other countries. We should be leading in financial innovation, not pushing this activity offshore to less regulated places. Regulation is necessary, but it needs to be balanced. I appreciate the CFTCs focus on issues like manipulation and insider trading, as raised in Questions 1-6 and 29-32 of the ANPR. I agree these are real concerns, but the answer isnt to shut down prediction markets. The CFTC already has strong tools to combat fraud and manipulation in other derivatives markets. Those can be adapted here without punishing everyone for the actions of a few bad actors.


    I urge you to support proportionate regulation that allows prediction markets to thrive while addressing specific risks. Lets keep this innovative tool accessible to regular people like me, not just big institutions, and ensure the U.S. remains a leader in this space. Thank you for considering my perspective.


    Sincerely,

    Kevin McCullough

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