Comment Text:
Dear Chairman and Commissioners,
My name is Brandon Underwood, and I'm just a regular citizen from Massachusetts writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been trading on platforms like Kalshi for a while now, and I believe these markets are a valuable tool that shouldn't be overly restricted. I appreciate the chance to weigh in on how the CFTC can regulate them sensibly.
For me, prediction markets aren't about gambling or speculation for fun. They're a practical way to manage real financial risks in my life. For example, I run a small side business selling handmade goods, and political or economic events like elections or changes in trade policy can directly impact my costs and sales. Trading on Kalshi lets me hedge against some of that uncertainty, like betting on an election outcome that might affect taxes or tariffs. It's not perfect, but it gives me a bit of control over risks that otherwise Id just have to sit and worry about. I think a lot of small business owners and everyday people like me could benefit from this kind of tool if its kept accessible.
I understand there are concerns about things like insider trading or manipulation, and those are valid. But the CFTC already has laws and tools to crack down on bad actors in other markets, and I believe those can work here too. Shutting down or over-regulating prediction markets to stop a few cheaters would hurt people like me who use them responsibly. It's like closing a highway because some drivers speed. Just enforce the rules we already have.
I also want to address a couple of specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think allowing prediction markets under clear rules strikes that balance. Theyre innovative because they give regular folks access to information and hedging tools, and protection comes from CFTC oversight, not bans. And on Question 15, about defining gaming versus legitimate markets, Id argue these contracts arent gaming when theyre tied to real-world risks people face, like economic or policy changes. Theyre more like insurance or other financial tools.
Im not an expert, just someone who sees the value in these markets. I hope the CFTC will support proportionate regulation that lets prediction markets operate while addressing specific risks with targeted rules. Please dont ban or overly restrict them, as that would take away a useful option for people like me trying to manage uncertainty in our lives.
Thank you for considering my perspective.
Sincerely,
Brandon Underwood
