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Comment for Proposed Rule 91 FR 12516

  • From: Richard Humphrey
    Organization(s):

    Comment No: 117332
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Richard Humphrey, and I'm a trader and investor based in Texas. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to individuals like me and to society as a whole, and I urge the CFTC to craft proportionate regulations rather than overly restrictive rules or bans.


    As someone who trades regularly, Ive seen firsthand how prediction markets offer insights you just can't get elsewhere. Ive watched these platforms consistently outperform polls and pundits when it comes to forecasting events, whether it's an election outcome or an economic indicator. For example, during the last presidential election cycle, the odds on Kalshi were a better gauge of the race than most national polls I followed. That kind of accuracy isnt just helpful for traders like me; its valuable for businesses, policymakers, and everyday people trying to make sense of an uncertain world. If the U.S. wants to stay competitive in financial innovation, we cant afford to stifle tools that aggregate information this effectively.


    I understand there are concerns about manipulation or insider trading, and those aren't trivial. But the CFTC already has strong tools to address these issues in other markets, and they can be applied here too. Banning or over-restricting prediction markets because of a few potential bad actors feels like punishing the majority for the sins of a few. Plus, pushing these markets offshore to unregulated platforms would be worse for everyone. Id rather see the U.S. lead the way with smart oversight, ensuring transparency and fairness while keeping innovation alive.


    On specific points raised in the ANPR, I want to address Questions 7 and 8 under the Public Interest section. Prediction markets absolutely serve the public good through better price discovery, and the CFTC should weigh that heavily against risks. Innovation shouldnt be curbed just because there are challenges to solve. And to Question 15 on defining legitimate markets versus gaming, Id argue these arent gambling. Trading on Kalshi takes research and judgment, much like trading stocks or futures. Its about informed decision-making, not luck.


    Im asking the CFTC to support a regulatory framework that allows prediction markets to thrive under clear, fair rules. Dont let the fear of misuse derail a tool thats proven its worth for forecasting and risk management. The U.S. has a chance to be a leader in this space, and I hope youll take it.


    Sincerely,

    Richard Humphrey

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