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Comment for Proposed Rule 91 FR 12516

  • From: Dylan Phillips
    Organization(s):

    Comment No: 117319
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Dylan Phillips, and I'm a student from Nebraska writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I have a personal interest in this issue because I actively trade on prediction markets like Kalshi, and I believe these platforms offer real value to people like me and to society as a whole.


    As a student, Im always looking for better ways to understand the world, whether it's politics, economics, or other major events. Prediction markets provide information that I just can't get from polls or news outlets. The prices on these platforms often cut through the noise and give a clearer picture of what might happen, whether its an election result or an economic indicator. I think this kind of price discovery isnt just helpful for traders, its useful for everyone, including policymakers and the public who can benefit from more accurate forecasts.


    I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi let regular people like me have a stake in understanding and predicting real-world outcomes. Its not gambling, its about research and judgment, much like investing in stocks. If we ban or over-restrict these markets, that freedom disappears, and I worry it would push activity to unregulated offshore platforms. Id much rather trade on a CFTC-registered exchange where there are rules and oversight than on some shady foreign site with no protections. Regulation keeps us safe, but bans just drive things underground.


    Regarding some of the specific questions in the ANPR, I want to address Question 7 on balancing innovation and consumer protection. I believe the CFTC can protect consumers by regulating prediction markets without stifling them. Focus on enforcing existing laws against manipulation and insider trading, which you already have the power to do, rather than broad prohibitions. Also, in response to Question 14 about the public interest, I think well-regulated prediction markets serve the public by providing transparent information and allowing everyday citizens to participate in financial systems, not just big institutions.


    Im not blind to the concerns about manipulation or insider trading, but shutting down these markets isnt the answer. Punish the bad actors, not the rest of us who use these platforms responsibly. The CFTC already has tools to handle fraud in other markets, and I trust you can adapt those here.


    I urge you to support proportionate regulation of prediction markets. Dont ban or over-restrict them. Keep platforms like Kalshi accessible and safe for people like me who value the information and opportunity they provide. Thank you for considering my perspective.


    Sincerely,

    Dylan Phillips

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