Comment Text:
Dear Chairman and Commissioners,
My name is Ryan Brubaker, and I'm a software engineer from Wisconsin. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I strongly support the development of well-regulated prediction markets in the United States, and I want to share why I believe they are valuable and why over-restricting them would be a mistake.
I've been trading on prediction markets for a while now, and I find them incredibly useful for getting insights that I can't find anywhere else. The prices reflect real-time collective knowledge, often more accurate than polls or news pundits. But beyond just information, these markets let me hedge personal financial risks. For instance, as someone in tech, policy changes or economic shifts tied to elections or regulatory decisions can impact my job stability or freelance contracts. Trading on event contracts helps me offset some of that uncertainty, much like how I might use other financial tools to manage risk. This isn't gambling to me. It takes research, analysis, and judgment, just like any other investment.
I'm particularly concerned with the idea of classifying event contracts as gaming, as raised in Questions 15-22 of the ANPR. These contracts serve legitimate economic purposes, like price discovery and hedging, which are far from the characteristics of gambling. Labeling them as such risks stifling a tool that benefits individuals like me and even small businesses in my network who use these markets to manage risks tied to policy or economic outcomes. I also worry that overly restrictive rules could push activity to unregulated offshore platforms, which are far less safe than CFTC-regulated markets like Kalshi. I've seen firsthand how transparent and accountable a regulated platform can be, and I'd hate to see that replaced by sketchy alternatives. This ties directly to Questions 7-14 on public interest: the balance should favor innovation and access over excessive restriction.
Another point I want to stress is the importance of the US leading in financial innovation. As a tech professional, I know how fast the world moves. If we clamp down too hard on prediction markets, we risk ceding ground to other countries that embrace these tools. That would be a loss for American competitiveness, and I hope the CFTC considers this in its approach to Questions 33-40 on classification and costs.
I understand there are concerns about manipulation or insider trading, but the CFTC already has tools to address these issues. Let's not punish everyone by limiting access to these markets. Instead, I urge you to craft proportionate regulations that protect consumers while allowing regular people like me to participate in legal, regulated prediction markets. Don't ban or over-restrict them. Thank you for considering my perspective.
Sincerely,
Ryan Brubaker
