Comment Text:
Dear Chairman and Commissioners,
My name is Bryce Ferguson, and I'm a small business owner based in California. I run a retail business here, and Ive been actively trading on prediction markets like Kalshi for the past couple of years. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support well-regulated prediction markets, and I hope my perspective as a regular user can help inform your approach.
For me, prediction markets arent just a hobby; theyre a valuable tool. Ive seen firsthand how the prices on these platforms often predict outcomes more accurately than polls or TV pundits. When Im making business decisions, like planning inventory around potential economic shifts or policy changes, I check prediction market data alongside other sources. Its not perfect, but its often sharper than anything else out there. This kind of information shouldnt be locked away for just big institutions; regular people like me benefit from having access to it.
I also believe that the United States should be a leader in financial innovation. If we over-restrict or ban prediction markets, we risk pushing this activity to offshore platforms where theres no oversight. Id much rather trade on a regulated market like Kalshi, under the CFTCs watch, than be forced to use some sketchy foreign site with no consumer protections. Regulation is important, but it needs to be balanced. Broad categorical bans dont solve problems; they just create new ones. Targeted rules that address specific risks, like manipulation, make more sense.
On the topic of whether event contracts are gambling, I have to push back. Trading on these markets takes research and judgment, just like investing in stocks. Im not rolling dice; Im making informed bets based on real-world events. These contracts serve a real economic purpose, whether its hedging against policy changes that could hit my business or just gaining insight into whats likely to happen. I think Question 15 in your ANPR, about defining gaming versus legitimate markets, gets at this, and Id urge you to recognize the clear difference.
Im also concerned with Questions 7 and 8 on balancing innovation and consumer protection. I want protections in place, absolutely, but shutting down or overly restricting these markets isnt the way to protect people. It just drives us to less safe alternatives. Proportionate regulation that keeps markets open while tackling bad actors is the right path.
I appreciate the chance to weigh in. Please support a framework that allows prediction markets to operate under fair, targeted rules. Dont let over-regulation or bans push this innovation out of reach for people like me.
Sincerely,
Bryce Ferguson
