Comment Text:
Dear Chairman and Commissioners,
My name is Ryland Brickner-McDonad, and I'm just an everyday citizen from New Jersey. I'm writing to share my thoughts 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 I believe well-regulated prediction markets are valuable for me and for society as a whole. I want to urge the CFTC to support these markets with fair, proportionate rules instead of overly restrictive bans.
I started trading on prediction markets because I wanted better information about elections and other public events. Honestly, the forecasts on these platforms have consistently been more accurate than what I see from polls or pundits on TV. That kind of insight helps me make sense of the world, and I think it benefits everyone, not just traders like me. It's also about having the freedom to participate in legal, regulated markets. I don't see this as gambling. When I trade on Kalshi, I'm researching, reading news, and using my judgment about real-world events. It feels a lot like investing in stocks, not rolling dice. These event contracts serve real economic purposes, like price discovery, and I believe they shouldn't be classified as gaming.
I'm also worried about what happens if the CFTC over-restricts or bans these markets. I've seen unregulated offshore platforms out there, and they're far riskier than a regulated space like Kalshi. Banning prediction markets won't stop people from trading; it'll just push activity to less safe places. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. I trust those can be adapted here without throwing out the whole concept. Plus, informed trading actually improves price discovery. When people with knowledge trade, the prices get more accurate, and that helps everyone.
On the topic of innovation, I think the US should be leading the way in financial markets like these, not leaving it to other countries. I also appreciate the academic research behind prediction markets, which shows how they aggregate information efficiently. In response to some of the questions in the ANPR, like those in Topic B on public interest (Questions 7-14), I believe the balance should tip toward innovation with consumer protection through regulation, not prohibition. For Topic C on listed activities (Questions 15-22), I urge you to avoid labeling these contracts as gaming when they have clear economic value.
I understand there are concerns about manipulation or insider trading, but shutting down entire markets to stop a few bad actors feels like punishing everyone else. Please focus on targeted rules that address specific risks. I strongly support proportionate regulation of prediction markets to keep them accessible, safe, and innovative for people like me.
Thank you for considering my input.
Sincerely,
Ryland Brickner-McDonad
