Comment Text:
Dear Chairman and Commissioners,
My name is Brian Comerford, and I'm an engineer based in Texas. I'm writing to provide my input on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the development of well-regulated prediction markets in the United States. I believe these markets provide unique value and should not be overly restricted or banned.
As an engineer, I value data and accuracy. Prediction markets have consistently produced forecasts for elections and other public events that are more reliable than traditional polls or pundit opinions. I've seen this firsthand on Kalshi, where the collective judgment of traders often cuts through the noise of media spin. This isn't just helpful for those of us trading; it's a public good that benefits journalists, policymakers, and everyday citizens who want clearer insights into what's likely to happen. I think the CFTC should recognize this forecasting value, especially when considering Questions 7 and 8 in your ANPR about balancing innovation with public interest.
I also believe in the freedom to participate in legal, regulated markets. Platforms like Kalshi operate under CFTC oversight, which gives me confidence as a consumer that there are safeguards against fraud or manipulation. Banning or over-restricting these markets would likely push activity to unregulated offshore platforms where there’s no accountability. I've looked at some of those sites, and they’re a mess compared to a regulated exchange. Addressing Question 11 on consumer protection, I’d argue that regulation, not prohibition, is the best way to keep participants safe.
Another point I want to make is that event contracts are not gambling. Trading on these markets requires research and analysis, much like investing in stocks or commodities. I’m often weighing real-world data when deciding whether to bet on an election outcome or an economic indicator. It’s a legitimate economic activity, and informed trading actually improves price discovery, which helps everyone. On Question 29 about inside information, I’d say that while bad actors should be prosecuted, the presence of informed traders generally makes the market’s predictions sharper and more useful.
I’m not blind to the risks. Manipulation and insider trading are real concerns, but the CFTC already has tools to address them. Shutting down entire markets to stop a few bad apples feels like overkill to me. Instead, I urge you to focus on proportionate rules that target specific problems without stifling innovation or pushing activity offshore.
In closing, I ask the CFTC to support the growth of regulated prediction markets. They’re a valuable tool for forecasting, hedging, and civic engagement, and with the right oversight, they can thrive safely. Please don’t let heavy-handed restrictions undermine this potential.
Sincerely,
Brian Comerford
