Comment Text:
Dear Chairman and Commissioners,
My name is Daniel Moncrief, and Im a law student based in Georgia. Im writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, Ive seen firsthand the value these markets provide, and I believe the CFTC has an opportunity to foster innovation while protecting consumers with thoughtful rules.
For me, trading on prediction markets isnt just a hobby. Its a legitimate source of side income that lets me apply my legal knowledge and analytical skills to real-world events. Ive used these markets to hedge personal financial risks tied to election outcomes and policy changes that could impact my taxes or business environment. Beyond my own experience, I see prediction markets as a powerful tool for society. They consistently produce forecasts for elections and public events that are more accurate than polls or pundits, providing valuable information for decision-making. This isnt gambling. These event contracts serve real economic purposes like price discovery and risk management, and classifying them as gaming ignores their utility.
Im particularly drawn to the idea that informed trading improves price discovery for everyone in the market, not just traders. Thats why I urge the CFTC to focus on proportionate, targeted regulation rather than broad categorical bans, as discussed in Questions 15-22 on listed activities. The CFTC already has robust tools to tackle manipulation and insider trading, as referenced in Questions 1-6 on core principles. Theres no need to reinvent the wheel. Use what works. Banning or over-restricting these markets would likely push activity to unregulated offshore platforms, which are far less safe than regulated exchanges like Kalshi. Questions 7-14 on public interest hit on this balance, and I believe the US should lead in financial innovation rather than cede ground to other countries.
I understand concerns about consumer protection and manipulation. Those are real. But shutting down entire markets to stop a few bad actors punishes law-abiding participants like me. Regulated markets are the answer, not bans. They keep activity transparent and under oversight. Academic research also backs this up, showing how prediction markets aggregate information efficiently. I hope the CFTC considers this data when addressing Questions 33-40 on classification and costs.
In closing, I ask the Commission to support well-regulated prediction markets with rules that address specific risks without stifling innovation or access. Lets keep these markets legal, safe, and open to Americans who want to participate. Thank you for considering my perspective.
Sincerely,
Daniel Moncrief
