Comment Text:
Dear Chairman and Commissioners,
My name is Thomas Casey, and I'm a finance professional based in Washington state. I've been actively trading on prediction markets like Kalshi for a few years now, and Im writing to express my strong support for well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to individuals like me, to businesses, and to society as a whole, and I urge the CFTC to adopt a balanced, proportionate approach to regulating them.
As someone who works in finance, I rely on accurate data to make informed decisions. Prediction markets consistently produce better forecasts for elections and major public events than polls or pundits. I've seen this firsthand on Kalshi, where the collective wisdom of traders often cuts through noise and bias. This isn't just useful for me as a trader; its valuable for anyone who needs reliable information, from policymakers to the general public. Beyond forecasting, these markets let me hedge personal and business financial risks. For instance, Ive used event contracts to offset uncertainty around economic policy changes that could impact my investments or clients. This isn't gambling. Its a legitimate economic tool, much like trading futures or options, and classifying it as "gaming" ignores its real purpose.
I also want to stress that regulated platforms like Kalshi are far safer than the alternative. If the CFTC over-restricts or bans these markets, activity will just move to unregulated offshore platforms with no oversight. I've seen enough in my career to know that pushing legitimate financial activity underground helps no one, least of all consumers. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. Those same tools can work here without resorting to broad categorical bans. Informed trading, in fact, improves price discovery and benefits everyone in the market, not just a few insiders.
Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets serve the public good through better information and risk management. On Topic Area C regarding listed activities (Questions 15-22), I urge you not to treat event contracts as gaming but as tools for economic purpose. And on Topic Area E about inside information (Questions 29-32), I think the focus should be on enforcing existing laws rather than restricting entire markets. Finally, the US has a chance to lead in financial innovation. We shouldn't cede that to other countries by over-regulating a promising sector.
I respectfully ask the CFTC to support proportionate regulation that addresses specific risks without stifling prediction markets. Lets keep these markets accessible, safe, and innovative for Americans like me who value their benefits.
Sincerely,
Thomas Casey
