Comment Text:
Dear Chairman and Commissioners,
My name is Noah Suhr, and I'm just a regular citizen 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, and I believe they have real value for people like me and for society as a whole. I want to urge the CFTC to support well-regulated prediction markets instead of overly restricting or banning them.
Ive always been interested in elections and big public events, and prediction markets have given me a way to engage with those topics in a unique way. Unlike polls or pundits, which often seem to miss the mark, the prices on these markets have consistently been more accurate in forecasting outcomes. That kind of information isnt just helpful for traders; its useful for everyone trying to understand whats happening in the world. Platforms like Kalshi have even motivated me to stay updated on current geopolitical affairs, which I think is a positive side effect of participating in these markets.
I also value the freedom to participate in legal, regulated markets. Having a platform like Kalshi, which operates under CFTC oversight, feels much safer than the alternative of unregulated offshore sites. If the U.S. clamps down too hard on prediction markets, I worry that activity will just move to those less secure places, putting users like me at greater risk. Regulation should keep us safe, not push us into the shadows. On top of that, I believe the U.S. should be a leader in financial innovation. We shouldnt let other countries take the lead on something that could be a powerful tool for information and economic activity.
I want to address a couple of specific questions from the ANPR. Regarding Question 7 on balancing innovation and consumer protection under the public interest topic, I think the CFTC can achieve both by setting clear rules for platforms like Kalshi while allowing them to operate. And for Question 29 on inside information, I believe the existing laws against insider trading are enough to handle bad actors without shutting down entire markets. The answer isnt to ban prediction markets; its to enforce the tools you already have.
Im not an expert, but as someone whos used these platforms, I can say theyre not gambling to me. Theyre a way to think critically about the world and make informed decisions. I hope the CFTC will craft proportionate regulations that let regular folks like me continue to participate in safe, legal prediction markets while addressing any real risks with targeted rules.
Thank you for considering my input.
Sincerely,
Noah Suhr
