Comment Text:
Dear Chairman and Commissioners,
My name is Christopher Batman, and Im a lawyer based in Arizona. Im writing to express my support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. While Im relatively new to these markets, Ive come to see their value as innovative tools for aggregating information and managing risk, and I believe the CFTC has a critical role in ensuring they operate safely and fairly without stifling their potential.
As a legal professional, I value the freedom to participate in legal, regulated markets. Prediction markets like those operated by Kalshi, a CFTC-registered designated contract market, offer a transparent and accountable environment for individuals to engage in informed trading. This stands in stark contrast to unregulated offshore platforms, which lack oversight and expose participants to significant risks. Banning or overly restricting prediction markets in the U.S. would not eliminate demand; it would simply push activity to these less safe venues, undermining consumer protection and the CFTCs authority. I urge you to keep these markets within a regulated framework.
I also believe the U.S. should lead in financial innovation rather than cede ground to other countries. Prediction markets are a cutting-edge tool, and with the right oversight, they can position the U.S. as a global leader in this space. The CFTC already has robust tools to address concerns like manipulation and insider trading in other derivatives markets. These can and should be adapted to event contracts without resorting to broad categorical bans. Proportionate, targeted regulation that addresses specific risks is far more effective than sweeping prohibitions that punish legitimate participants.
On the topic of informed trading, Id like to address questions 29 through 32 from the ANPR regarding inside information. Informed trading, when conducted legally, enhances price discovery and benefits all market participants by making prices more accurate. This isnt a flaw; its a feature of well-functioning markets. Existing laws already prohibit federal employees and others from trading on nonpublic information, and the CFTCs anti-manipulation powers are broad enough to tackle bad actors without shutting down entire markets.
In closing, I ask the CFTC to support the continued development of prediction markets through balanced regulation. Lets keep these markets legal, transparent, and accessible under your oversight, rather than driving them offshore or stifling innovation with overly restrictive rules. Thank you for considering my perspective as you shape this important policy.
Sincerely,
Christopher Batman
