Comment Text:
Dear Chairman and Commissioners,
My name is Caleb Dalgleish, and Im a trader and investor based in Washington, D.C. Im writing to share my perspective on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi and Polymarket, and I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to individuals like me, as well as to society at large, and I urge the CFTC to craft rules that encourage innovation while addressing legitimate risks.
As a trader, Ive seen firsthand how prediction markets offer insights you cant get from polls or pundits. Ive relied on these platforms to gauge election outcomes and economic indicators, and their forecasts are often more accurate than traditional sources. This isnt just useful for me; its valuable for anyone making decisions, whether its a business owner planning around policy changes or a regular person trying to understand the world. Beyond that, these markets let me hedge real risks. For instance, Ive used event contracts to offset potential impacts of interest rate decisions on my investments. This isnt gambling. Its a calculated move based on research and judgment, much like trading stocks or futures.
I also want to stress that event contracts serve legitimate economic purposes and shouldnt be lumped in with gaming, as discussed in Questions 15-22 of the ANPR. These markets are about price discovery and risk management, not luck. Calling them gambling would be like calling any investment speculative. Plus, regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, activity will just move to less transparent venues, as hinted at in Questions 7-14 on public interest. Thats worse for consumer protection, not better.
On the topic of manipulation and insider trading, raised in Questions 29-32, I believe the CFTC already has strong tools to tackle bad actors. These issues are illegal across all markets, and the focus should be on enforcement, not blanket prohibitions. Banning prediction markets to stop a few cheaters punishes everyone else, including traders like me who play by the rules. And honestly, the U.S. should be leading in financial innovation, not ceding ground to other countries. We have the chance to set the standard for how these markets work, and I hope we take it.
Im not blind to the risks. Consumer protection matters, and oversight is necessary. But the answer is proportionate regulation, not heavy-handed restrictions. I urge the CFTC to support prediction markets with clear, fair rules that keep them accessible to everyday people while ensuring transparency and accountability. Lets keep this innovation alive and thriving in the U.S.
Thank you for considering my input.
Sincerely,
Caleb Dalgleish
