Comment Text:
Dear Chairman and Commissioners,
My name is Jordan Keiser, and I'm a regular citizen from New Jersey writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm new to prediction markets, but I've been learning a lot through platforms like these, and I strongly support their development under fair, well-thought-out regulation. I believe they offer real value to people like me and to society as a whole, and I want to explain why.
First, I've seen how prediction markets often predict outcomes for elections and other public events better than polls or pundits. That kind of accuracy isn't just interesting, it's useful. It helps regular folks like me make sense of complex issues and could even guide better public decision-making. I also appreciate that these markets let everyday people participate in a legal, regulated space. Shutting that down or over-restricting it would just push activity to unregulated offshore platforms, which feels way riskier to me. I'd rather see a platform like Kalshi, under CFTC oversight, than have no safe options at all.
I also think prediction markets aren't gambling. They take research and judgment, just like investing in stocks. They serve real purposes, like helping people or businesses hedge against risks. For example, I could see myself using these markets to offset uncertainty around economic policies that affect my budget. Classifying them as "gaming" doesn't seem right to me when they have clear economic value. On top of that, I worry that banning or harshly limiting these markets would hurt US competitiveness. We should be leading in financial innovation, not letting other countries take the reins.
I'm not ignoring the risks, though. I get that manipulation or insider trading could be issues, but the CFTC already has strong tools to tackle those problems in other markets. Why not adapt those here instead of broad bans? I also believe informed trading actually helps. It makes prices more accurate, which benefits everyone, not just traders. I'm glad to see the CFTC asking about these points in questions 7 through 14 on public interest and 29 through 32 on inside information. My take is simple: focus on proportionate rules that target specific risks rather than shutting down entire categories of contracts.
In the end, I urge the CFTC to support prediction markets with balanced regulation. Don't ban or over-restrict them. Keep them safe and accessible for regular people like me while maintaining US leadership in this space. Thank you for considering my perspective.
Sincerely,
Jordan Keiser