Comment Text:
Dear Chairman and Commissioners,
My name is Ian Marderness, and I'm a trader and investor from Florida. I'm writing to provide my input on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on prediction markets like Kalshi for a while now, and I strongly support the idea of well-regulated prediction markets rather than heavy restrictions or outright bans.
I rely on platforms like Kalshi not just for potential profits but for real economic utility. Trading event contracts has allowed my family to make additional income, which has been a big help in covering everyday expenses. More than that, these markets let me hedge against risks that affect my financial life, like changes in interest rates or election outcomes that could impact taxes or regulations. This isn't gambling to me. It takes research and judgment, just like trading stocks or futures. Classifying event contracts as gaming, as discussed in Questions 15-22 of the ANPR, ignores their legitimate purpose in price discovery and risk management.
I'm also concerned about what happens if the CFTC over-restricts these markets. Banning or heavily limiting prediction markets won't stop people from trading; it'll just push activity to unregulated offshore platforms where there are no protections. I've seen how Kalshi operates under CFTC oversight, with clear rules and transparency. Thats far safer than the alternative. Regulated markets keep participants like me protected and ensure the CFTC can monitor for manipulation or other issues, as raised in Questions 1-6 on core principles.
On the public interest side, addressed in Questions 7-14, I believe prediction markets serve a real purpose for society. They help aggregate information in ways polls and pundits can't match. And for individuals and businesses, they offer a tool to hedge against uncertainty, whether it's a policy change or an economic event. Shutting this down or over-regulating it would take away a valuable resource and send innovation elsewhere.
I understand there are concerns about insider trading or manipulation, as mentioned in Questions 29-32. But those issues are already illegal under existing laws, and the CFTC has the tools to enforce them. Punishing everyone by restricting prediction markets because of a few bad actors doesn't make sense. Focus on enforcement, not bans.
I urge the CFTC to support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules. Don't let over-restriction push this valuable tool offshore or out of reach for people like me who use it responsibly. Thank you for considering my perspective.
Sincerely,
Ian Marderness
