Comment Text:
Dear Chairman and Commissioners,
My name is Jason Givens, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and Im writing to express my strong support for well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to society and to people like me who rely on accurate information to make decisions.
Ive seen firsthand how prediction markets often produce forecasts that are more accurate than polls or pundits. Whether it's an election outcome or an economic indicator, the prices on these platforms cut through the noise and give a clearer picture of whats likely to happen. This isn't just helpful for traders; its valuable for anyone who needs reliable data, from journalists to policymakers. As someone who makes a living assessing risks and probabilities, I cant overstate how useful this is.
What worries me is the idea of banning or over-restricting these markets. Ive traded on both regulated platforms like Kalshi, which operate under CFTC oversight, and unregulated offshore ones like Polymarket. The difference in safety and transparency is night and day. Regulated markets have rules, oversight, and accountability. Offshore platforms? Not so much. If we clamp down too hard here, people like me will just move to less safe venues outside the US. That doesnt solve any problems; it makes them worse. Instead, the US should be leading the charge in financial innovation. We cant afford to cede this space to other countries that are more willing to embrace new ideas.
On the topic of insider trading, which I know is a concern for the CFTC, Ill be blunt. If youre worried about people using nonpublic information, look at Congress and other federal insiders. There are already laws against trading on privileged info, so enforce those. Dont punish the rest of us by shutting down markets that are open and transparent. Im also aware of the academic research backing prediction markets, like studies by economists showing how they aggregate information efficiently. This isnt gambling; its a tool for better decision-making.
Id like to address a couple of your specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think the focus should be on smart regulation, not outright bans. And on Question 29, regarding informed traders and price discovery, I believe those with better information make the markets more accurate, as long as theyre not breaking laws to get it. Lets keep these markets accessible and well-regulated.
I urge you to support proportionate regulation of prediction markets. Dont let fear of a few bad actors derail a system that benefits so many. The US can lead here, and I hope youll help make that happen.
Sincerely,
Jason Givens