Comment Text:
Dear Chairman and Commissioners,
My name is Landen Andrews, and I'm a trader and investor based in Colorado. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi and Polymarket, and I strongly support the proportionate regulation of prediction markets rather than over-restrictive bans or broad prohibitions.
As a trader, I value prediction markets because they let me participate in the bigger geopolitical conversation with real skin in the game. When I trade on election outcomes or public events, I'm not just guessing. I'm putting my analysis and research to the test, and the financial stake sharpens my focus. I've noticed something fascinating: the implied probabilities on these platforms often shift before the news breaks. Its a sign someone knows something, and if you're paying attention, you can ride that wave and come out better informed. It's an elegant system, honestly. These markets aren't just a game for me; they produce forecasts that are consistently more accurate than polls or pundits. That benefits everyone, not just traders like me.
I also use these markets to hedge real risks. Whether it's an election that could impact my taxes or a policy change that might affect my investments, prediction markets give me a tool to manage uncertainty. This isn't gambling. Its a legitimate economic activity, much like trading stocks or commodities. Classifying event contracts as "gaming" (as discussed in Questions 15-22) ignores their role in price discovery and risk management. They serve a purpose that goes beyond mere speculation.
I'm all for consumer protection, but the answer isn't to ban or overly restrict these markets. Regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If you push too hard with restrictions, activity will just move to less safe venues. On that note, I believe the CFTC already has strong tools to tackle manipulation and insider trading (as raised in Questions 29-32). Informed trading actually improves price discovery and benefits all participants. Instead of broad bans, focus on enforcing the rules you already have.
I also worry about U.S. competitiveness. We should be leading in financial innovation, not ceding ground to other countries (relevant to Questions 7-14 on public interest). Proportionate, targeted regulation addresses specific risks without killing the market. Academic research backs this up, showing how prediction markets aggregate information efficiently. Lets build on that.
I urge the CFTC to support well-regulated prediction markets. Dont let over-restriction push traders like me offshore or stifle a tool that helps us all make sense of an uncertain world. Thank you for considering my input.
Sincerely,
Landen Andrews