Comment Text:
Dear Chairman and Commissioners,
My name is Jackson Gilroy, and I'm a trader and investor based in the United States. I've been involved in financial markets for years, always looking for tools that help me make informed decisions and manage risk. I'm relatively new to prediction markets, but I've quickly come to see their value, both for myself and for society. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets and to urge the CFTC to adopt a balanced, proportionate approach.
As a trader, I rely on accurate information to make decisions. Prediction markets stand out because they often produce forecasts that beat polls or pundits, especially on elections and major public events. That kind of aggregated insight is hard to find elsewhere, and it's not just useful for traders like me, it's valuable for the public and even policymakers. I also see real potential for hedging personal and business risks with these markets. For example, a small business owner could hedge against policy changes tied to an election outcome, or someone like me could offset financial uncertainty tied to economic data releases. This isn't gambling, it's a legitimate economic tool, much like trading stocks or commodities based on research and judgment. Classifying event contracts as "gaming" (as discussed in Questions 15-22) ignores their real purpose in price discovery and risk management.
I'm also concerned about the alternative if prediction markets are over-restricted or banned. Regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore sites. If the U.S. clamps down too hard, activity will just move to less transparent venues, undermining consumer protection (a point raised in Questions 7-14). The CFTC already has strong tools to tackle manipulation and insider trading, as seen in other derivatives markets. Use those tools, don't punish everyone by shutting down legitimate markets. And let's not forget, informed trading actually improves price discovery, benefiting all participants, not just a few (relevant to Questions 29-32).
The U.S. should be a leader in financial innovation, not cede ground to other countries. Prediction markets are backed by solid academic research showing their value in aggregating information. I want the freedom to participate in legal, regulated markets that provide better data for decision-making. Overly broad bans or restrictions won't solve specific risks like insider trading, they'll just push innovation and capital offshore.
I urge the CFTC to craft targeted regulations that address real concerns without stifling this emerging market. Focus on proportionate rules, not categorical prohibitions. Prediction markets have too much potential for accurate forecasting, risk hedging, and public benefit to be sidelined.
Thank you for considering my perspective.
Sincerely,
Jackson Gilroy
