Comment Text:
Dear Chairman and Commissioners,
My name is Sam Bryan, and I'm a software engineer based in New York. I work in tech, where data and innovation drive everything we do, and Ive been an active trader on prediction markets like Kalshi for a while now. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) because I strongly support well-regulated prediction markets and believe they offer real value to individuals like me, businesses, and society as a whole.
As someone who trades on these platforms, Ive seen firsthand how prediction markets provide information you cant get anywhere else. Their forecasts often beat polls or pundits, whether its about election outcomes or economic indicators. Thats not just useful for traders; its valuable for anyone making decisions, from policymakers to regular citizens. I also use these markets to hedge personal financial risks. For instance, Ive traded on contracts tied to interest rate decisions since those directly impact my plans for a mortgage. This isnt gambling. Its a practical way to manage uncertainty, much like any other investment.
Im also concerned about freedom and fairness. Prediction markets let people like me participate in a legal, regulated space. If the CFTC over-restricts or bans these markets, itll push activity to unregulated offshore platforms, which are far less safe. Id much rather trade on a platform like Kalshi, under CFTC oversight, where there are consumer protections in place. Plus, the US should be leading in financial innovation. If we clamp down too hard, we risk ceding that edge to other countries.
I know there are worries about manipulation or insider trading, and I get it. Those are real risks. But the CFTC already has strong tools to tackle these issues in other derivatives markets. Theres no need for broad bans when targeted rules can address specific problems. Informed trading, in my view, actually helps. It improves price discovery and makes the markets predictions more accurate for everyone. Shutting down entire categories of contracts to stop a few bad actors punishes the rest of us and doesnt solve the root issue.
Id like to touch on a few of your specific questions from the ANPR. On Question 7 under Public Interest, I believe prediction markets balance innovation and consumer protection when regulated properly, as Ive experienced with Kalshi. On Question 29 under Inside Information, I think informed traders often improve market accuracy, and existing laws already bar federal insiders from abusing nonpublic info. And on Question 33 regarding Classification, I urge you to avoid overly burdensome rules that could hurt small participants like me.
Prediction markets are great, plain and simple. They help people hedge risks, make better decisions, and engage with the world around them. I ask the CFTC to support proportionate regulation that addresses specific risks without banning or over-restricting these valuable tools. Thank you for considering my input.
Sincerely,
Sam Bryan
