Comment Text:
Dear Chairman and Commissioners,
My name is Israel Deal, and I'm a software engineer from Texas. Ive spent years in the tech world, where data and innovation drive everything I do. Im writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). Ive used prediction markets a few times myself, and I strongly support their existence under sensible, proportionate regulation. I believe theyre a powerful tool for individuals like me, businesses, and society as a whole.
As someone who works with data daily, I value the unique information prediction markets provide. They often forecast election outcomes or public events more accurately than polls or pundits. Thats not just useful for traders; its valuable for anyone making decisions, from policymakers to regular folks. Beyond forecasting, these markets let me hedge real financial risks. For instance, as a tech professional, Im affected by policy shifts or economic changes tied to elections or regulations. Being able to hedge against those uncertainties helps me plan better. This isnt gambling. Its a thoughtful process, much like investing in stocks, requiring research and judgment about the real world.
I also believe that regulated platforms like Kalshi are far safer than unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, activity will just move to less transparent, riskier venues outside U.S. oversight. That hurts consumers like me who want to participate legally and safely. The U.S. should be leading in financial innovation, not ceding ground to other countries. Were a tech-driven nation, and prediction markets are part of that future.
Addressing some of your specific questions, like those in Topic B on public interest (Questions 7-14), I think the CFTC should prioritize balancing innovation with consumer protection through targeted rules, not broad bans. On Topic E about inside information (Questions 29-32), I believe informed trading actually improves price discovery and benefits everyone by making prices more accurate. The CFTC already has robust tools to tackle manipulation and insider trading in other derivatives markets; those can be applied here without shutting down entire categories of contracts. Finally, on Topic C regarding listed activities (Questions 15-22), I urge you to recognize that event contracts serve legitimate economic purposes like hedging and forecasting, not gaming.
I understand concerns about potential misuse, but banning or over-restricting these markets punishes the majority of honest participants. Proportionate regulation that targets specific risks is the better path. I ask the CFTC to support well-regulated prediction markets, ensuring they remain a legal, accessible tool for Americans while maintaining strong safeguards against abuse.
Thank you for considering my input.
Sincerely,
Israel Deal
