Comment Text:
Dear Chairman and Commissioners,
My name is Brian Kurzweil, and I'm a finance professional based in California. I've worked in the financial sector for years, analyzing markets and understanding how information drives prices. I've also used prediction markets a few times myself, and Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets serve a valuable purpose and deserve thoughtful, proportionate regulation rather than outright bans or overly restrictive rules.
As someone who follows markets closely, Ive seen firsthand how prediction markets often produce forecasts that are more accurate than polls or pundits. They aggregate information in a way thats unique, and that benefits not just traders but anyone who relies on data to make decisions. Ive also used these platforms to hedge personal financial risks tied to economic or political events, and I know businesses that do the same for things like regulatory changes or policy outcomes. This isnt gambling; its a legitimate tool for managing uncertainty, much like other derivatives markets I work with daily. Classifying event contracts as gaming ignores their real economic purpose.
Im especially concerned about the idea of over-restricting or banning these markets. Regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If we push activity underground by being too heavy-handed, we lose oversight and expose participants to greater risks. The U.S. should be leading in financial innovation, not ceding ground to other countries. Plus, the CFTC already has strong tools to tackle issues like manipulation and insider trading. Use those existing powers instead of broad prohibitions that punish everyone for the actions of a few.
I also want to address some specific questions in the ANPR. On Questions 7-14 under Public Interest, I believe the balance between innovation and consumer protection lies in targeted rules, not categorical bans. On Questions 29-32 about Inside Information, Id argue that informed trading actually improves price discovery and benefits all participants by making markets more efficient. And regarding Questions 15-22 on Listed Activities, event contracts serve hedging and forecasting purposes that are distinct from gaming and should be regulated as such.
I urge the CFTC to support the freedom to participate in legal, regulated prediction markets. Focus on proportionate regulation that addresses specific risks without stifling a valuable tool. Lets keep these markets accessible, safe, and innovative right here in the U.S.
Thank you for considering my input.
Sincerely,
Brian Kurzweil
