Comment Text:
Dear Chairman and Commissioners,
My name is Willie Nunley, and I'm a small business owner from Florida. I run a local company here, dealing with the ups and downs of economic shifts and policy changes that impact my bottom line. I've also been an active trader on prediction markets like Kalshi for a while now, and I'm writing to support well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets are valuable, not just for me but for society, and I want to share why I think the CFTC should regulate them proportionately rather than restrict or ban them.
Prediction markets give me information I can't get anywhere else. As a business owner, I rely on accurate forecasts to plan inventory and staffing, especially around big events like elections or federal policy decisions. I've seen firsthand how these markets often predict outcomes better than polls or pundits. That data helps me make smarter decisions, and it's not just useful for traders like me; it benefits the public and even policymakers who need clear signals about what might happen next. Beyond that, I use these markets to hedge real risks. For instance, Ive traded contracts tied to economic indicators like CPI data because inflation directly affects my costs. This isn't gambling; it's a practical tool, much like any other investment I make to protect my business.
Im also concerned about freedom and fairness. I appreciate that platforms like Kalshi are regulated by the CFTC, which makes them safer than unregulated offshore sites. If you over-restrict or ban these markets, people like me will get pushed to less safe venues, and thats a step backward. The U.S. should be leading in financial innovation, not handing that edge to other countries. Plus, academic research backs this up; studies show prediction markets improve information transparency and aggregate knowledge efficiently. Informed trading, even if its by people with strong insights, actually sharpens price discovery and helps everyone.
Addressing some of your specific questions, like those in Topic Area B (Questions 7-14) on public interest and price discovery, I strongly believe these markets serve a legitimate economic purpose, not gaming. Theyre about research and judgment, just like trading stocks. And on Topic Area E (Questions 29-32) regarding inside information, I think the CFTC already has solid tools to tackle manipulation and insider trading. You dont need broad bans; you need to enforce whats already in place. Banning entire categories to stop a few bad actors punishes honest participants like me.
I urge you to support proportionate regulation that targets specific risks without stifling innovation or access. Prediction markets are a powerful tool for businesses and individuals, and with the right oversight, they can thrive safely under CFTC rules. Thank you for considering my perspective.
Sincerely,
Willie Nunley
