Comment Text:
Dear Chairman and Commissioners,
My name is Jack Ngiraibuuch, and I'm a trader and investor based in Kentucky. I've been working in financial markets for years, focusing on ways to manage risk and make informed decisions. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets. I believe they are a valuable tool for individuals like me, as well as for society at large, and I urge the CFTC to craft rules that allow these markets to thrive under fair oversight.
I've personally used prediction markets to hedge financial risks that affect my investments and personal finances. For instance, I've traded contracts tied to election outcomes and economic indicators like inflation reports to offset potential impacts on my portfolio. These markets let me protect myself against uncertainty in a way that traditional investments often can't. It's not gambling; it's a calculated approach based on research and real-world analysis, much like trading stocks or commodities. Beyond my own use, I see how prediction markets consistently produce forecasts that are more accurate than polls or pundits. The aggregated wisdom of many traders often beats so-called experts, and that kind of information is useful to everyone, not just those of us who participate.
I'm also a firm believer in the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore alternatives. If heavy restrictions or bans are put in place, people won't just stop trading; they'll move to less secure venues where there's no protection. That hurts regular traders like me and undermines the whole point of regulation. Plus, I think the US has a chance to lead in financial innovation here. If we over-regulate or shut these markets down, we're handing that advantage to other countries.
I want to address a concern I know the CFTC has, particularly around manipulation or insider trading, as raised in questions 29-32 of the ANPR. I get why this is a worry, but the answer isn't to ban or overly restrict prediction markets. Laws already exist to prevent insider trading and market manipulation, and the CFTC has the authority to enforce them. Focus on using those tools rather than punishing the majority of honest participants. On the public interest side, as discussed in questions 7-14, I believe prediction markets serve a real purpose in hedging risks for individuals and businesses, and that outweighs the potential downsides if proper safeguards are in place.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Don't ban broad categories of contracts or create barriers that push activity offshore. Instead, craft rules that protect consumers while allowing innovation and access for everyday traders like me. Thank you for considering my input.
Sincerely,
Jack Ngiraibuuch
