Comment Text:
Dear Chairman and Commissioners,
My name is Brett Church, and I'm a student and academic based in Montana. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I want to express my strong support for the proportionate regulation of prediction markets, and I hope my perspective as someone who actively engages with these platforms can offer some useful insight.
As part of my academic work, I test strategies in small quantities and build economic models to compare their outcomes. Prediction markets, like Kalshi, have become an invaluable tool for me. I trade on these platforms not just to test theories but to gauge consumer expectations, which often drive other financial and economic decisions I study. The data and forecasts these markets produce are often more accurate than traditional polls or pundit opinions. I've seen firsthand how the aggregated wisdom of many traders cuts through noise and bias in a way that few other sources can match. This isn't just helpful for me as a student; it's a public good that benefits anyone seeking clarity on future events.
I also believe that regulated prediction markets are far safer than the alternative. Platforms like Kalshi, operating under CFTC oversight, provide transparency and accountability that unregulated offshore markets simply don't. If we over-restrict or ban these markets in the US, activity won't stop; it will just move to less safe, less transparent venues. That hurts everyone, from individual traders like me to the broader financial system. Plus, the US has a chance to lead in financial innovation. We shouldn't cede that ground to other countries by stifling a promising sector.
I often use prediction markets to hedge personal financial risks tied to economic or policy outcomes, and I know others who do the same for business risks. This isn't gambling; it's a practical tool. Regarding some of the specific questions in the ANPR, like those in Topic B on public interest (Questions 7-14), I urge you to consider how prediction markets support price discovery and risk management. On Topic E, about inside information (Questions 29-32), I acknowledge the concern, but existing laws already prohibit insider trading, and the CFTC has tools to enforce them. Banning or over-restricting these markets to address a few bad actors would punish the many who use them responsibly.
As an academic, I also value the research potential of transparent data from these markets. The information they generate could inform studies and policy in ways we're only beginning to explore. I ask that you craft regulations that allow prediction markets to thrive under fair oversight, without broad prohibitions or excessive barriers.
Thank you for considering my input.
Sincerely,
Brett Church
