Comment Text:
Dear Chairman and Commissioners,
My name is Bryce DeGroat, and I'm a business owner from New York running a football-related business. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the development of well-regulated prediction markets in the United States, and I want to share my perspective as someone who actively trades on platforms like Kalshi and Polymarket.
As a small business owner, I deal with uncertainty every day, whether it's about economic conditions, regulatory changes, or even weather events that can impact my operations. Prediction markets have become a valuable tool for me. I use them to hedge risks that affect my business, like potential policy shifts or economic data releases that could change my costs or customer demand. This isn't gambling, not by a long shot. It takes research and real-world judgment to trade on these platforms, much like investing in stocks or futures. Classifying event contracts as "gaming," as discussed in Questions 15-22 of the ANPR, ignores their legitimate economic purpose. They help me make informed decisions and protect my livelihood, which is far from a game of chance.
I'm also worried about what happens if these markets are banned or over-restricted. I've traded on offshore platforms like Polymarket, and I can tell you they're not as safe or transparent as regulated U.S. markets like Kalshi. If the CFTC clamps down too hard, people like me will have no choice but to go offshore, where there's little to no consumer protection. Addressing Questions 7-14 on public interest, I believe regulation should balance innovation with safety, not push activity into unregulated spaces. The U.S. should lead in this space by setting clear, fair rules that keep markets here under oversight.
I understand there are concerns about manipulation or insider trading, as raised in Questions 29-32. But banning entire markets to stop a few bad actors isn't the answer. The CFTC already has tools to combat fraud and manipulation in other derivatives markets. Use those tools here. Don't punish small business owners and everyday traders who rely on these markets for real economic reasons.
I urge the CFTC to craft proportionate regulations that allow prediction markets to thrive while addressing specific risks with targeted rules. Please don't ban or overly restrict event contracts. Keep them accessible, regulated, and safe for people like me who use them responsibly.
Sincerely,
Bryce DeGroat
