Comment Text:
Dear Chairman and Commissioners,
My name is Jacob Downing, and I'm just a regular guy from Texas whos taken an interest in prediction markets. I actively trade on platforms like Kalshi, and 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 the idea of well-regulated prediction markets and believe the CFTC should focus on proportionate rules rather than heavy restrictions or bans.
I got into trading on prediction markets because I wanted a way to engage with real-world events that affect my life, like elections or economic policies. Platforms like Kalshi give me a chance to put my research and judgment to work, and Ive found the information from these markets to be incredibly useful, often more accurate than polls or news commentary. This isnt gambling to me. Its about making informed decisions, just like I would with stocks or other investments. Classifying event contracts as "gaming" feels wrong when they serve a real economic purpose, whether its hedging risks or figuring out whats likely to happen.
What worries me most is the idea of over-restricting or banning these markets. If that happens, people like me wont just stop trading. Well get pushed to unregulated offshore platforms that dont have the safeguards of a CFTC-registered exchange like Kalshi. Id much rather trade in a market where theres oversight and accountability. Regulation done right keeps us safe, but too much restriction just moves the activity to riskier places. I think the CFTC should focus on targeted rules to address specific problems, like manipulation or insider trading, instead of broad categorical bans.
I also believe the U.S. should be a leader in financial innovation. If we clamp down too hard, other countries will take the lead, and well miss out on the benefits of these markets. Look at how accurate prediction markets have been on things like election outcomes. Thats valuable for everyone, not just traders. Regarding some of the questions in the ANPR, like those in Topic Area B on public interest (Questions 7-14), I think the balance should lean toward innovation with smart oversight, not prohibition. And on Topic Area C about listed activities (Questions 15-22), I urge you not to label these contracts as gaming when theyre clearly tied to economic utility.
Im not an expert or a lawyer, just a citizen who values the freedom to participate in legal, regulated markets. I hope the CFTC will support prediction markets with fair rules that protect traders without shutting down this useful tool. Please dont over-restrict or ban them. Focus on regulation that works for regular people like me.
Thank you for considering my input.
Sincerely,
Jacob Downing
