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Comment for Proposed Rule 91 FR 12516

  • From: Geoff Linsley
    Organization(s):

    Comment No: 115411
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,

    My name is Geoff Linsley, and I'm a business owner from the United States. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I've seen firsthand how valuable these markets are, not just for me, but for society as a whole.

    As a business owner, I rely on accurate information to make decisions that affect my bottom line. Prediction markets consistently provide forecasts on elections and other public events that are more reliable than polls or pundits. This isn't just a hunch; the data backs it up. I also use these markets to hedge real financial risks tied to policy changes or economic shifts that could impact my business, like interest rate decisions or regulatory outcomes. It's a practical tool, not a game. Classifying event contracts as "gaming" ignores their legitimate economic purpose, and I urge you to recognize their role in price discovery and risk management, as raised in Questions 7 and 15 of your ANPR.

    I'm also concerned about freedom and fairness. These markets let regular people like me participate in a system that generates better information for everyone, not just big institutions. Banning or over-restricting them would push activity to unregulated offshore platforms, which are far less safe than CFTC-regulated markets like Kalshi. I've traded on both types of platforms, and the difference in transparency and consumer protection is night and day. Your Questions 7 and 33 touch on balancing innovation with protection, and I believe regulated markets are the answer, not prohibition. The U.S. should be leading in financial innovation, not ceding ground to other countries.

    On the issue of manipulation or insider trading, I get the concern. But the CFTC already has strong tools to tackle these problems in other derivatives markets, and those can be adapted here without broad bans. Informed trading actually improves price discovery, benefiting all participants, as noted in Question 29. Shutting down entire markets to stop a few bad actors punishes honest users like me. It's worth noting that pushing markets offshore only makes oversight harder.

    Finally, I want to say something personal. I believe prediction markets are more than just financial tools; they're a way to understand reality better. They label uncertainty where it exists and enhance the human experience. I even see this as tied to free expression under the First Amendment, a kind of secular pursuit of truth. The war on event prediction needs to stop. Instead of categorical restrictions, I ask you to focus on targeted, proportionate rules that address specific risks without stifling innovation.

    Thank you for considering my input. I strongly support well-regulated prediction markets and hope the CFTC will craft rules that allow them to thrive while protecting participants.

    Sincerely,
    Geoff Linsley

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