Comment Text:
Dear Chairman and Commissioners,
My name is Mitch Hull, and I'm a trader and investor from the United States. I've been in the markets for a while, focusing on ways to make informed decisions with my money. I've used prediction markets a few times, and Im writing to support well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe they offer real value, both to me personally and to society, and Id like to share why I think the CFTC should regulate them proportionately rather than restrict or ban them.
As a trader, Ive seen firsthand how prediction markets provide information you cant get anywhere else. Theyve consistently been more accurate than polls or pundits when it comes to forecasting elections and other public events. That kind of insight helps me make better financial decisions, and its not just useful for traders like me. Its valuable for businesses, policymakers, and even regular folks trying to understand whats coming next. I also use these markets to hedge personal and business risks, like the impact of an election outcome on my taxes or a policy change that could affect my investments. This isnt gambling, in my view. It takes research and judgment, just like trading stocks or commodities. Classifying event contracts as gaming feels wrong when they serve legitimate economic purposes like price discovery and risk management.
Im aware of concerns about manipulation or insider trading, and I get why those are issues. But the CFTC already has strong tools to tackle these problems in other derivatives markets. Those same tools can work here. Banning or over-restricting prediction markets doesnt solve the problem; it just pushes activity to unregulated offshore platforms where theres no oversight at all. Id much rather see a regulated market like Kalshi, under CFTC supervision, than have traders forced to less safe venues. Plus, informed trading actually improves price discovery. When knowledgeable participants trade, the market gets more accurate, and that benefits everyone.
I also want to address some of your specific questions from the ANPR. On Public Interest (Questions 7-14), I think prediction markets balance innovation with consumer protection when theyre regulated properly. Theyre a tool for better decision-making, not a risk to the public. On Listed Activities (Questions 15-22), event contracts shouldnt be lumped in with gaming; theyre about real-world outcomes and economic utility. And on Inside Information (Questions 29-32), I believe informed traders help, not hurt, as long as existing laws against insider trading are enforced.
The U.S. has a chance to lead in financial innovation with prediction markets. We shouldnt cede that to other countries by over-regulating. I urge you to focus on targeted, proportionate rules that address specific risks without broad bans. Lets keep these markets safe, accessible, and useful for everyone.
Thank you for considering my input.
Sincerely,
Mitch Hull
