Comment Text:
Dear Chairman and Commissioners,
My name is Jordan Gross, and I'm a public policy professional based in New York. I work in government and policy, so I see every day why it's critical to hold companies accountable when they step out of line. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets, with a focus on proportionate rules rather than broad bans.
I actively trade on prediction markets like Kalshi and Polymarket, and I've found them incredibly valuable for forecasting elections and public events. As someone who analyzes policy for a living, I can say these platforms often provide insights that polls and pundits just don't capture. The aggregated wisdom of many traders creates a clearer picture of what might happen, whether it's a tight Senate race or a major regulatory shift. This isn't gambling to me; it's a tool for understanding the world, and I believe it benefits society when everyday people like me can participate alongside bigger players. Keeping this information accessible makes our democracy stronger by giving regular citizens a stake in understanding public events.
That said, I have real concerns based on personal experience. I've had issues with Kalshi where I believe they failed to pay out on trades that should have been settled in my favor. Multiple times, I've lost money I felt was rightfully mine, and there's no clear mechanism to hold them accountable. This isn't just frustrating; it's a sign that regulation is urgently needed. Without oversight, platforms like Kalshi can cheat users like me, and others will keep getting burned. This is why I support the CFTC stepping in with targeted rules to ensure fairness and transparency.
I'm particularly drawn to questions 7 and 23 in your ANPR, about balancing innovation with consumer protection and when public interest determinations should happen. I think the CFTC should focus on specific risks, like ensuring platforms honor their contracts and preventing manipulation, rather than banning entire categories of event contracts. Broad bans punish honest users and push trading to unregulated offshore sites, which is worse for everyone. Proportionate regulation can address bad actors without killing a useful tool.
I also want to address concerns about insider trading or manipulation. These are real issues, but the answer isn't shutting down prediction markets. Laws already exist to stop federal employees or others from trading on nonpublic info, and the CFTC has tools to tackle manipulation in other markets. Use those tools here. Don't punish the majority for the actions of a few.
In closing, I urge the CFTC to support prediction markets with fair, targeted regulation. Platforms like Kalshi need oversight to prevent abuse, but these markets provide real value for forecasting and civic engagement. Let's not throw out a good thing over fixable problems.
Sincerely,
Jordan Gross
