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Comment for Proposed Rule 91 FR 12516

  • From: Jed Kelly
    Organization(s):

    Comment No: 116908
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Jed Kelly, and I'm a finance professional from Massachusetts. I've been working in the financial industry for years, and I've also dabbled in prediction markets a few times through platforms like Kalshi. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my support for well-regulated prediction markets and to urge the CFTC to adopt a balanced, targeted approach to regulation.


    As someone who understands markets, I believe prediction markets offer unique value. They aggregate information in ways that polls and pundits often can't match, and they give regular folks like me a chance to participate in assessing real-world events. I've used these markets to gauge outcomes that impact my financial planning, and I value the freedom to engage in legal, regulated platforms. Banning or over-restricting these markets would shut out everyday people and concentrate information among big institutions. Thats not right.


    I also think the US has a chance to be a leader in financial innovation here. If we overregulate or impose broad categorical bans, we risk pushing this activity to offshore, unregulated platforms where there's less oversight and more risk. I've seen how regulated markets work in my professional life, and I know that targeted rules can address specific concerns like manipulation or insider trading without throwing out the whole concept. The CFTC already has tools to tackle bad actors. Use them, but don't punish the rest of us with sweeping prohibitions.


    On a personal note, I'm a big sports betting fan. I love the idea of betting on sports through a CFTC-regulated platform like Kalshi. Here's why: regulated sportsbooks are often tied down by state taxes and heavy gaming regulations, which can force them to offer worse odds to cover their costs. A CFTC-regulated market could theoretically provide better odds for consumers like me since it wouldn't be burdened by those same state-level expenses. This is just one example of how regulation under the CFTC can benefit participants directly.


    Id like to address a couple of questions from the ANPR. Regarding Question 7 on balancing innovation and consumer protection, I believe proportionate regulation achieves both by allowing access while enforcing existing laws against manipulation. And for Question 15 on defining legitimate markets versus gaming, I argue that prediction markets, even for sports, serve economic purposes like price discovery and hedging, distinct from pure gambling.


    In closing, I ask the CFTC to support prediction markets with thoughtful, targeted rules rather than broad restrictions. Keep the US at the forefront of financial innovation and preserve access for regular people like me. Thank you for considering my perspective.


    Sincerely,

    Jed Kelly

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