Comment Text:
Dear Chairman and Commissioners,
My name is Kimberly McClure, and I'm a trader and investor based in New Jersey. I've been actively trading on prediction markets like Kalshi for a while now, and I'm 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 people like me, as well as to society at large, and I hope the CFTC will craft rules that allow them to thrive without over-restricting access.
As someone who trades regularly, I've seen firsthand how prediction markets offer information you can't get anywhere else. They're often more accurate than polls or pundits when it comes to forecasting elections and other public events. That kind of insight isn't just helpful for traders; it benefits everyone by improving public decision-making. I rely on these markets to get a clearer picture of what's likely to happen, whether it's an election outcome that could impact my investments or a policy change that might affect my financial planning. It's not gambling. It takes research and real-world judgment, just like trading stocks or commodities.
I also use prediction markets to hedge real risks. For example, I've traded contracts tied to election outcomes because the results can directly affect tax policies that impact my income as an investor. This isn't just playing a game; it's a practical tool to manage uncertainty. I know businesses use these markets too, to hedge against regulatory or economic shifts. Classifying event contracts as "gaming" feels wrong to me. They serve legitimate economic purposes, and I urge the CFTC to recognize that distinction when considering Question 15 about defining gaming versus legitimate markets.
I'm also a firm believer in the freedom to participate in legal, regulated markets. Allowing everyday people like me to trade on platforms like Kalshi democratizes access to valuable information. If only big institutions could participate, all that insight would stay locked away with them. Plus, informed trading by people with knowledge actually improves price discovery, which helps everyone. On Question 29 about inside information, I'd argue that informed traders often make markets more accurate, as long as existing laws against insider trading are enforced. We don't need bans; we need the CFTC to use the tools it already has to prevent manipulation.
I understand there are concerns about abuse or insider trading, but shutting down or overly restricting prediction markets isn't the answer. Punishing the majority for the actions of a few bad actors doesn't make sense. The CFTC already has authority to tackle manipulation and fraud, and those tools should be applied here too.
I respectfully ask the CFTC to support proportionate regulation of prediction markets. Please don't ban or over-restrict them. Craft rules that address specific risks while allowing these markets to continue providing valuable forecasting and hedging opportunities for people like me.
Sincerely,
Kimberly McClure
