Comment Text:
Dear Chairman and Commissioners,
My name is Will Dan, and I'm a finance professional based in New York. I've been working in the financial sector for years, analyzing markets and trends, and Ive found prediction markets to be an invaluable tool. I actively trade on platforms like Kalshi, and Im writing to express my strong support for proportionate regulation of prediction markets as outlined in the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets serve a critical purpose for individuals like me and for society at large.
In my experience, prediction markets consistently produce more accurate forecasts than traditional polls or pundit opinions, especially for elections and major public events. Ive seen this firsthand. During the last election cycle, while polls and media outlets were all over the place, the prices on prediction markets gave a clearer, more grounded picture of what was likely to happen. That kind of insight isnt just useful for traders; its valuable for anyone trying to understand the world, from journalists to policymakers. As someone who relies on accurate data in my day-to-day work, I cant overstate how much this matters.
Beyond forecasting, these markets also let me hedge personal and business financial risks tied to uncertain events. For instance, Ive used prediction markets to offset potential impacts from policy changes or economic shifts that could affect my investments or clients portfolios. This isnt gambling, its a practical tool. It takes research and judgment, just like any other financial instrument I deal with. Banning or over-restricting these markets would strip away a resource that helps me manage risk effectively.
I also want to address a concern I know the CFTC is wrestling with, specifically around insider trading and manipulation, as raised in Questions 29-32 of the ANPR. I get the worry about bad actors, but the answer isnt to shut down prediction markets. Laws already exist to prevent insider trading by federal employees or anyone with nonpublic information, and the CFTC has the authority to tackle market manipulation. Enforce those rules instead of punishing everyone by limiting access to these markets. It would be like closing the stock market because of a few insider trading cases. Thats not fair or logical.
On Questions 7-14 about public interest, Id argue that prediction markets balance innovation and consumer protection when regulated properly. They democratize access to information and let regular people like me participate, which makes the forecasts stronger and fairer. If only big institutions can play, the benefits stay locked away.
I urge the CFTC to support well-regulated prediction markets rather than imposing broad bans or overly tight restrictions. Keep these markets accessible and safe through targeted rules that address specific risks without killing the value they provide. Thank you for considering my perspective.
Sincerely,
Will Dan
