Comment Text:
Dear Chairman and Commissioners,
My name is Jackson Erminio, and I'm a small business owner from South Carolina. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the idea of well-regulated prediction markets in the United States. I believe they offer real value, both to people like me and to our countrys position as a leader in financial innovation.
As a business owner, Ive found prediction markets to be a useful tool. They give me insights into events that impact my business, like economic policy changes or election outcomes that could affect taxes and regulations. The information I get from these markets often feels more reliable than what I see in the news or polls. Beyond that, trading on a regulated platform like Kalshi gives me confidence that theres oversight and accountability. I know my trades are happening in a system thats watched by the CFTC, not some shady offshore site where anything goes.
Heres my main concern: if we ban or over-restrict prediction markets, were not stopping the activity. Were just pushing it to unregulated platforms overseas. Ive seen those sites out there, and theyre a mess. No oversight, no consumer protections, just a free-for-all. If people like me cant trade on a safe, regulated market in the US, many will take the risk and go offshore. Thats worse for everyone. Regulated markets keep things transparent and accountable, and they keep the activity here under your jurisdiction.
On top of that, I think the US should be leading the way in financial innovation. Weve always been the place where new ideas in finance take root, from stock markets to derivatives. Prediction markets are the next step, and if we stifle them with heavy-handed rules, were handing that leadership to other countries. I want the US to be the hub for this kind of innovation, not Europe or Asia. This ties directly to some of the questions in your ANPR, like Question 7 on balancing innovation with consumer protection. I believe we can have both, with smart, targeted rules that address real risks without killing the market.
Im not blind to the concerns about manipulation or insider trading. Those are real issues. But the CFTC already has tools to tackle fraud and manipulation in other markets, and those can work here too. Dont punish the majority of honest traders by shutting down or over-restricting prediction markets because of a few bad actors.
I urge you to support proportionate regulation of prediction markets. Let platforms like Kalshi operate under clear, fair rules that protect consumers while fostering innovation. Keep the US at the forefront of financial markets, and dont drive this activity offshore with overly strict policies.
Thank you for considering my input.
Sincerely,
Jackson Erminio