Comment Text:
Dear Chairman and Commissioners,
My name is Michael Arnopp, and I'm just an everyday citizen from Nevada writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I strongly support the idea of well-regulated prediction markets. I appreciate the CFTC taking the time to gather public input before drafting rules, and I hope my perspective as a regular user can help shape a balanced approach.
I believe prediction markets are incredibly valuable, both for me personally and for society as a whole. I've seen firsthand how their forecasts on elections and other public events often beat out polls or pundits. That kind of information isn't just useful for traders like me; it's helpful for everyone trying to make sense of what's coming next. Beyond that, these markets let me hedge real risks. For example, Ive placed trades on election outcomes that could impact my taxes or local business regulations here in Nevada. This isn't gambling to me. It takes research and judgment, much like any other investment I might make in stocks or commodities. Classifying event contracts as "gaming" feels wrong when they serve such clear economic purposes.
I'm also worried about what happens if these markets get banned or over-restricted. Right now, I can trade on regulated platforms like Kalshi, where theres oversight and consumer protection. But if the rules get too tight, people like me will just turn to unregulated offshore platforms. Thats not safer for anyone. Id much rather see the CFTC focus on proportionate regulation that keeps activity in the U.S., under your watch. The U.S. should be leading the way in financial innovation, not pushing it overseas.
On some of the specific questions in the ANPR, like those in Topic B on public interest (Questions 7-14), I think the balance should lean toward innovation while still protecting consumers through targeted rules. And on Topic C (Questions 15-22), I urge you not to label these contracts as gaming. Theyre a legitimate tool for forecasting and hedging. Also, regarding Topic E on insider trading (Questions 29-32), I believe the CFTC already has strong tools to tackle manipulation and insider trading in other markets. Those can be adapted here without resorting to broad bans that punish honest participants like me.
Im not blind to the risks. I know some bad actors might try to manipulate prices or trade on inside info. But shutting down or overly restricting prediction markets isnt the answer. It just hurts regular folks while the real problems move offshore. Instead, I ask you to support proportionate regulation that addresses specific risks without killing off the benefits these markets bring.
Thank you for considering my input.
Sincerely,
Michael Arnopp
