Comment Text:
Dear Chairman and Commissioners,
My name is Garrett DeGraw, and I'm just a regular citizen from Idaho writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been actively trading on platforms like Kalshi for a while now, and I strongly support the idea of well-regulated prediction markets. I believe they provide unique value to people like me and to society as a whole, and I hope the CFTC will create rules that allow these markets to thrive without over-restricting them.
As someone who isn't a Wall Street insider or a big-time investor, I value the chance to participate in legal, regulated markets like Kalshi. These platforms let me have a stake in understanding and predicting real-world events, whether it's an election outcome that could impact my taxes or a Federal Reserve decision that might affect my cost of living. The information I get from prediction market prices is often sharper than what I see in polls or hear from pundits. It's not just useful for my own decisions; it helps everyone by creating better public data for decision-making. I think keeping these markets open to everyday people, not just big institutions, is fair and makes the prices more accurate.
I also want to stress that trading on prediction markets isn't gambling. It takes research and judgment about real events, much like trading stocks or commodities. Classifying event contracts as "gaming" doesn't make sense to me when they serve real economic purposes like hedging and price discovery. I'm not betting for fun; I'm making informed decisions based on what I learn.
That said, I get why consumer protection matters. I've seen unregulated offshore platforms out there, and they're a real risk compared to a CFTC-regulated market like Kalshi. If the CFTC bans or over-restricts prediction markets, people will just move to those shadier venues where there's no oversight. Regulation is the answer, not prohibition. The CFTC already has strong tools to tackle manipulation and insider trading in other markets. Use those same tools here instead of broad categorical bans. Targeted, proportionate rules can address specific risks without punishing everyone else.
I'm also worried that over-regulating could mean the U.S. loses its edge in financial innovation. We should be leading the way on new ideas like prediction markets, not handing that advantage to other countries. On a related note, I think informed trading actually helps markets by improving price discovery, which benefits all participants. This ties into questions 7 and 29 from your ANPR, about balancing innovation with protection and the role of informed traders. I urge you to prioritize rules that support innovation while keeping markets safe and fair.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Keep platforms like Kalshi accessible to regular folks like me under a strong but fair regulatory framework. Thank you for considering my perspective.
Sincerely,
Garrett DeGraw
