Comment Text:
Dear Chairman and Commissioners,
My name is Robert Sapp, and I'm a business owner from Florida. Im writing to share my support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi and Polymarket, and Ive seen firsthand how these markets provide unique value to people like me, as well as to the broader public.
As a business owner, I rely on accurate information to make decisions, especially when it comes to economic or political events that can impact my operations. Prediction markets have consistently given me better forecasts than polls or pundits. For instance, during the last election cycle, I used market data to anticipate potential policy shifts that could affect my supply chain costs. That kind of insight isnt just helpful for traders; its valuable for anyone paying attention to public events. These markets also let me hedge real financial risks. A sudden change in federal regulations or tariff policies can hit my bottom line hard, and trading on event contracts helps me offset some of that uncertainty.
I strongly believe event contracts arent gambling. They take research and judgment, just like trading stocks or commodities. Classifying them as gaming would be a mistake when they serve clear economic purposes like price discovery and risk management. Im also concerned that banning or over-restricting these markets would push activity to unregulated offshore platforms. Id much rather trade on a regulated market like Kalshi, under CFTC oversight, where there are consumer protections in place. The U.S. should be leading the way in financial innovation, not handing that advantage to other countries.
I appreciate that the CFTC is asking for input on specific risks, like manipulation or insider trading, as raised in Questions 1-6 and 29-32. I agree those are valid concerns, but the agency already has strong tools to tackle fraud and manipulation in other derivatives markets. Those same tools can work here. Plus, informed trading often improves price discovery, which benefits everyone. Banning entire categories of contracts to stop a few bad actors feels like punishing the wrong people. Targeted, proportionate rules make more sense, as discussed in Questions 7-14 on balancing innovation and protection.
I urge the CFTC to support prediction markets with fair, practical regulations that address specific risks without stifling their benefits. Lets keep these markets accessible to regular people like me, and ensure the U.S. stays at the forefront of financial innovation. Thank you for considering my perspective.
Sincerely,
Robert Sapp
