Comment Text:
Dear Chairman and Commissioners,
My name is Gabe Greenfield, and I'm a software engineer based in Washington state. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on regulated prediction markets like Kalshi, I strongly support the CFTC crafting proportionate regulations for event contracts rather than imposing broad restrictions or bans.
I got into prediction markets a couple of years ago because I saw how they provide unique insights you cant find anywhere else. Whether its forecasting election outcomes or economic indicators, the data from these markets often beats out polls or pundits. As a tech professional, I value hard data and transparency, and I believe these markets help everyday people, businesses, and even policymakers make better-informed decisions through accurate price discovery. Plus, Ive used them personally to hedge risks, like potential policy changes that could impact my freelance tech consulting income.
I understand there are concerns about manipulation or insider trading, but I dont think the answer is to over-restrict or ban these markets. Regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If you make it too hard to trade legally in the US, activity will just move to less transparent, riskier venues. Thats worse for consumer protection, not better. And lets be clear, event contracts arent gambling. They serve real economic purposes, like hedging and information aggregation. I spend hours researching before I place a trade, just like I would for any investment. Treating this as gaming feels like a mischaracterization.
I also think the US has a chance to lead in financial innovation here. As someone in tech, I see how fast other countries are moving on new financial tools. If we over-regulate, we risk ceding that leadership. On specific questions in the ANPR, like Question 7 on balancing innovation and protection, Id urge you to prioritize rules that target specific risks, like manipulation, without stifling the entire market. And on Question 29 about informed trading, I believe traders with good information actually improve price discovery, which benefits everyone, not just participants.
Im not saying there shouldnt be rules. I want consumer protections and fair markets as much as anyone. But broad categorical bans punish the wrong people. Focus on enforcing existing laws against insider trading and manipulation, and adapt those tools for prediction markets. Let regular folks like me keep participating in legal, regulated spaces.
Thank you for considering my input. I urge the CFTC to support proportionate regulation of prediction markets and avoid overly restrictive measures that could harm innovation and push activity offshore.
Sincerely,
Gabe Greenfield
