Comment Text:
Dear Chairman and Commissioners,
My name is Michael Pearcey. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been trading on platforms like Kalshi on and off for 7 years.
I firmly support well-regulated prediction markets. I believe they provide unique value to people like me and to society as a whole. For example, election markets provide real-time alternatives to polls and pundits. I hope that the CFTC will craft rules that allow these markets to thrive without over-restricting them.
I've never been particularly interested in news and politics. But ever since I found prediction markets, I've become much more engaged. With mention markets in particular... in the past, I never would have watched a president's speech or similar events, but now I watch most of the president's livestreams. I'm much more tuned in to what's happening in the country than I would be without mention markets.
I also want to stress that regulated markets are a much safer space for people like me compared to unregulated offshore platforms. If the CFTC bans or overly restricts prediction markets, I worry that activity will just get pushed to those less safe venues where theres no oversight. Id much rather trade on a platform like Kalshi and PredictIt, under CFTC rules, where I know theres some level of consumer protection. Banning or crippling these markets doesnt solve problems; it creates new ones by driving people to riskier alternatives.
I also think that many event contracts are not gambling. Rather, they serve as a real-time, alternative source of information for important issues. I use my judgment and research to trade, just like I would for any other investment. Calling this "gambling", the same word used for a slot machine at the casino, is not accurate. In fact, I have never gambled, and I have never been even slightly interested in gambling.
In response to some of the specific questions in the ANPR, like those in Topic Area B about public interest (Questions 7-14), I believe prediction markets balance innovation with consumer needs when theyre properly regulated. And on Topic Area D (Questions 23-28), I think the CFTC should focus on proportionate, targeted rules rather than broad categorical bans. Address specific risks like manipulation or insider trading with existing tools instead of shutting down entire markets.
I urge the CFTC to support prediction markets with fair, balanced regulation that lets everyday people like me continue to participate in these legal, regulated spaces. Thank you for considering my perspective.
Sincerely,
Michael Pearcey
