Comment Text:
Dear Chairman and Commissioners,
My name is Daniel Ingersoll, and I'm a healthcare professional running a small business here in California. Im writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive used prediction markets a few times myself, and I strongly support their existence under fair, targeted regulation. I hope the CFTC will craft rules that allow these markets to thrive while addressing specific risks without broad, heavy-handed restrictions.
Running a business in California, I deal with endless regulations that often feel like overkill. They bog down my operations and cost me time and money, even when the intent behind them is good. Ive learned firsthand that targeted rules work better than sweeping bans or one-size-fits-all policies. Thats why Im concerned about any approach to prediction markets that might lean toward outright prohibitions or overly broad limits. I believe these markets have real value, both for me personally and for society, and they deserve a regulatory framework that lets them operate safely.
Ive found prediction markets to be incredibly useful for getting accurate forecasts on elections and other public events. Honestly, their predictions often beat out polls or pundits by a wide margin. That kind of insight helps me make better decisions for my business, especially when political outcomes could impact healthcare policies or taxes here in California. Beyond my own use, I see these markets as a public good. They aggregate information in a way that benefits everyone, not just traders. Plus, letting regular people like me participate isnt a flaw, its a strength. It democratizes access to information and makes the forecasts sharper.
I also want to stress that event contracts arent gambling. They serve real economic purposes, like helping people hedge risks or gain clarity on uncertain events. Calling them gaming feels like a misstep, akin to labeling stock trading as gambling. And on the topic of risks like insider trading or manipulation, I get the concern. But banning or over-restricting these markets isnt the answer. It just pushes activity to unregulated offshore platforms, which are far less safe than a regulated market like Kalshi. The CFTC already has tools to tackle bad actors. Use those instead of punishing everyone else.
Regarding some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets drive innovation and price discovery, and the US should lead in this space rather than cede ground to other countries. On Topic Area C about listed activities (Questions 15-22), I urge you to avoid treating these contracts as gaming. And on insider trading in Topic Area E (Questions 29-32), I think informed trading actually improves price discovery for all participants, as long as existing laws against misuse of nonpublic information are enforced.
Please support proportionate regulation that addresses specific risks without stifling prediction markets. Lets keep the US competitive and ensure these markets remain accessible under a fair, regulated framework.
Sincerely,
Daniel Ingersoll
