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Comment for Proposed Rule 91 FR 12516

  • From: Bryan Andre
    Organization(s):

    Comment No: 117401
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Bryan Andre, and I'm a software engineer based in Florida. Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, published in 91 FR 12516. As someone who actively trades on platforms like Kalshi and Polymarket, Ive seen firsthand the value these markets provide, and I believe the CFTC should regulate them proportionately rather than impose broad restrictions or bans.


    I work in tech, so Im naturally drawn to tools that aggregate data and provide transparency. Prediction markets do exactly that. They produce forecasts that are often more accurate than polls or pundits, which helps not just traders like me but also the public and even policymakers who need reliable information for decision-making. Beyond that, these markets let me hedge personal financial risks. For instance, Ive used them to offset potential impacts from election outcomes or economic policy changes that could affect my income or savings as a freelancer in a volatile industry. This isnt gambling; its a practical way to manage uncertainty, much like any other investment.


    Im also a firm believer in freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If you over-restrict or ban these markets, activity will just move to less transparent venues, which helps no one. The U.S. should be leading in financial innovation, not ceding ground to other countries. Weve got the talent and the infrastructure to set the global standard here.


    Addressing some of the specific concerns in your ANPR, particularly around manipulation and insider trading in Questions 1-6 and 29-32, I want to point out that the CFTC already has robust tools to tackle these issues. Market manipulation and insider trading are illegal, and your existing authority in other derivatives markets can easily apply to event contracts. Banning entire categories of contracts to stop a few bad actors feels like using a sledgehammer to crack a walnut. Targeted rules addressing specific risks make far more sense.


    On the public interest questions, like 7-14, Id argue that prediction markets serve a clear public good through price discovery and risk management. They democratize access to information and let regular people like me participate in a system that would otherwise be dominated by big institutions. Thats a feature worth protecting.


    I urge the CFTC to adopt a balanced approach that supports innovation while addressing legitimate risks with precise, proportionate regulation. Please dont let overbroad restrictions stifle a tool thats valuable for hedging, forecasting, and public transparency. Thank you for considering my perspective.


    Sincerely,

    Bryan Andre

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