Comment Text:
Dear Chairman and Commissioners,
My name is Ryan Lindemann, and I'm an everyday citizen from Virginia writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the idea of well-regulated prediction markets. I believe they provide unique value to people like me and to society as a whole, and I hope the CFTC will craft rules that allow these markets to thrive without over-restricting them.
As someone who participates in prediction markets, Ive seen firsthand how they offer information you cant find anywhere else. Whether its forecasting election outcomes or other public events, the prices on these platforms often cut through the noise of polls and pundits. Thats not just helpful for traders, its valuable for anyone trying to make sense of the world, including policymakers and the media. I also use these markets to hedge personal risks tied to economic or political changes, which feels more like investing than gambling. To me, calling event contracts "gaming" doesnt make sense. It takes research and judgment, just like trading stocks or commodities.
Im especially concerned about the idea of banning or overly restricting these markets. Platforms like Kalshi, which operate under CFTC oversight, are safe and transparent. If heavy restrictions push activity to unregulated offshore sites, thats worse for everyone. Its harder to protect consumers or prevent manipulation in those spaces. The CFTC already has strong tools to tackle issues like insider trading and market manipulation in other derivatives markets. I believe those same tools can work for prediction markets without needing broad prohibitions.
On the topic of innovation, I think the US should be a leader, not a follower. If we stifle prediction markets here, other countries will step in, and well lose the chance to shape this space. I also want to address concerns about insider trading, which I know the CFTC raises in questions 29 through 32 of the ANPR. Informed trading often improves price discovery, which benefits all participants. Bad actors should be punished, but shutting down entire markets to stop a few cheaters seems unfair and counterproductive.
Id also urge the CFTC to consider questions 15 through 22 on listed activities. Event contracts arent gambling, they serve real economic purposes like hedging and information aggregation. Classifying them as gaming would ignore their value. As a citizen, I value my freedom to participate in legal, regulated markets, and I hope the Commission will preserve that access.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Please dont ban or over-restrict them. Focus on targeted rules to address specific risks while allowing these markets to grow and provide their unique benefits to people like me and to the broader public.
Sincerely,
Ryan Lindemann
