Comment Text:
Dear Chairman and Commissioners,
My name is Keagan Dunn, a finance professional based in Washington state. Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, Ive seen firsthand the value these markets provide, and I believe the CFTC should craft proportionate regulations rather than impose broad restrictions or bans.
Prediction markets are a powerful tool for me, both personally and professionally. I use them to hedge risks tied to economic and political events that impact my financial planning, like potential changes in interest rates or election outcomes that could affect tax policies. This isnt gambling; its a legitimate way to manage uncertainty, much like trading futures or options in traditional markets. Beyond my own use, Ive noticed how these markets consistently produce forecasts more accurate than polls or pundits. That kind of information benefits everyone, from individuals making decisions to businesses and even policymakers who need reliable data. I also value the freedom to participate in legal, regulated markets like Kalshi, knowing theyre safer and more transparent than unregulated offshore platforms.
Id like to address a few specific questions from the ANPR. On Questions 7-14 regarding public interest, I believe prediction markets serve a clear public good through price discovery and risk management. They democratize access to information, and the U.S. should lead in this financial innovation rather than cede ground to other countries. On Questions 15-22 about listed activities, I strongly oppose classifying event contracts as gaming. These contracts serve real economic purposes, like hedging, and shouldnt be lumped in with gambling. As for Questions 29-32 on inside information, I think informed trading actually improves price discovery and benefits all participants. The CFTC already has robust tools to prevent manipulation and insider trading in other derivatives markets; those can and should be applied here without over-restricting access.
I understand concerns about potential abuse, but banning or overly restricting these markets isnt the answer. It would just push activity to unregulated offshore platforms, which are far riskier for consumers. Instead, targeted regulation addressing specific issues like manipulation makes more sense. The CFTC has the authority to tackle bad actors without punishing the rest of us who use these markets responsibly.
I urge you to support proportionate regulation of prediction markets. Lets keep the U.S. at the forefront of financial innovation while ensuring these markets remain safe and accessible for individuals and businesses alike. Thank you for considering my perspective.
Sincerely,
Keagan Dunn
