Comment Text:
Dear Chairman and Commissioners,
My name is Walter Mullins, and I'm a software engineer from Louisiana. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I strongly support the development of well-regulated prediction markets in the United States. I believe they provide real value to people like me, and I want to share why I think the CFTC should regulate them proportionately rather than restrict or ban them.
As someone in the tech industry, I often deal with uncertainty around policy changes or economic shifts that can impact my work and personal finances. Prediction markets have been a useful tool for me to hedge some of that risk. For instance, I've traded on contracts tied to interest rate decisions by the Fed, which helps me plan around potential changes in loan costs or project funding. This isn't gambling, it's a practical way to manage real financial exposure. I believe event contracts serve legitimate economic purposes, like price discovery and risk management, and shouldn't be lumped in with gaming as some might suggest.
I also worry about the idea of over-restricting these markets. The CFTC already has solid tools to handle issues like manipulation or insider trading in other derivatives markets. I trust those same tools can work here without needing broad bans that would hurt regular participants like me. Shutting down or overly limiting prediction markets would just push activity to unregulated offshore platforms, which is worse for everyone. Plus, as a tech professional, I think the US has a chance to lead in financial innovation. We shouldn't cede that ground to other countries by being too cautious or restrictive.
Looking at some of the specific questions in the ANPR, I want to address a couple that hit close to home. On Question 8 under Public Interest, about balancing innovation with consumer protection, I think regulated markets like Kalshi already strike a good balance by providing transparency and oversight while letting individuals participate. And on Question 15 under Listed Activities, regarding how to define gaming versus legitimate markets, Id argue that event contracts are more akin to other derivatives, requiring research and judgment, not luck. Theyre a tool, not a game.
I hope the CFTC will consider the benefits prediction markets offer to everyday people and businesses trying to navigate uncertainty. Please support proportionate regulation that allows innovation and participation while using existing safeguards to address risks. Dont let overly broad restrictions limit our freedom to engage in legal, regulated markets or push the industry overseas.
Thank you for considering my input.
Sincerely,
Walter Mullins
