Comment Text:
Dear Chairman and Commissioners,
My name is Doug Noel, and I'm an everyday citizen from Ohio writing to you about the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I want to share why I strongly support well-regulated prediction markets and why I believe the CFTC should adopt proportionate rules rather than broad restrictions.
I've found prediction markets to be incredibly valuable, not just for me but for society as a whole. The forecasts on platforms like Kalshi are often more accurate than polls or pundits when it comes to elections and major public events. Ive seen this firsthand tracking political outcomes that affect my taxes and local economy. These markets give me information I cant get anywhere else, and that benefits everyone, not just traders. Plus, theyve helped me hedge personal financial risks, like betting on economic indicators that impact my budget, such as inflation data affecting my grocery and rent costs. This isnt gambling. It takes research and real-world judgment, just like investing in stocks, which is why I dont think event contracts should be labeled as gaming. They serve a real economic purpose.
I also want to stress that regulated markets are far safer than the alternative. If the CFTC over-restricts or bans these platforms, people like me will just turn to unregulated offshore sites, which have no oversight. Id much rather trade on a CFTC-registered platform like Kalshi, where there are rules and protections. The US should be leading in financial innovation, not pushing it overseas. On a personal note, using Kalshi has taught me so much about markets that Ive even started my own 401k and built a small stock portfolio. This kind of democratized access to financial tools is empowering for regular folks like me.
Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets balance innovation with consumer protection when regulated properly. They help with price discovery and risk management, as Ive experienced myself. On Topic Area E about inside information (Questions 29-32), I think informed trading actually improves price accuracy and benefits all participants, and the CFTC already has strong tools to tackle manipulation and insider trading. Theres no need for broad bans when targeted enforcement can address bad actors.
Im not blind to the risks, like potential manipulation or insider issues. But shutting down or over-restricting these markets punishes honest participants like me. The answer is proportionate regulation that focuses on specific problems, not categorical prohibitions.
I urge you to support well-regulated prediction markets and avoid policies that would limit access or push activity offshore. Thank you for considering my perspective.
Sincerely,
Doug Noel
