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Comment for Proposed Rule 91 FR 12516

  • From: Christopher Robertson
    Organization(s):

    Comment No: 117242
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Christopher Robertson, and I'm a student from Texas writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've used prediction markets a few times myself, and I strongly support their continued operation under fair, proportionate regulation by the CFTC. I believe these markets provide unique value to society, especially for someone like me whos deeply interested in understanding public events and data.


    As a student, Ive always been fascinated by how we can predict outcomes for things like elections or major policy shifts. Ive seen firsthand that prediction markets often get closer to the truth than polls or pundits. When Ive traded on these platforms, Ive been able to access insights that just arent available anywhere else. Its not gambling to me; its a way to engage with real-world events, using research and critical thinking. Beyond my own use, I think these markets help everyone by aggregating information efficiently. Thats something academics like me value for research and transparency in data.


    I also care about the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, are far safer than unregulated offshore alternatives. If we over-restrict or ban these markets, people will just turn to less secure options outside U.S. jurisdiction, and thats worse for consumer protection. Regulation, not prohibition, is the answer. Im confident the CFTC already has strong tools to handle issues like manipulation or insider trading. Theres no need for broad bans when targeted enforcement can address specific bad actors.


    On top of that, I believe the U.S. should be a leader in financial innovation. If we stifle prediction markets, we risk ceding ground to other countries that are more open to new ideas. As someone studying these systems, Id hate to see the best research and opportunities move overseas. Id like to address a couple of specific questions from the ANPR. On Question 7, regarding public interest, I think prediction markets clearly serve the public by improving forecasting accuracy. On Question 29, about inside information, I believe informed traders actually help price discovery, and existing laws already bar federal officials from abusing nonpublic data.


    I urge the CFTC to support well-regulated prediction markets with rules that tackle real risks without shutting down the entire space. These markets are a powerful tool for understanding the world, and with the right oversight, they can thrive safely. Thank you for considering my perspective.


    Sincerely,

    Christopher Robertson

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