Comment Text:
Dear Chairman and Commissioners,
My name is Isa Bre, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing to express my strong support for well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to people like me and to society as a whole, and I want to share why I think the CFTC should focus on proportionate regulation rather than heavy restrictions.
As someone who trades regularly, I see prediction markets as a unique tool for gaining insights that I can't find anywhere else. The prices reflect real-world probabilities on everything from election outcomes to economic data releases, often more accurately than polls or expert opinions. Beyond that, these markets let me hedge personal risks. For instance, I've used event contracts to offset potential losses tied to policy changes that could impact my investments or tax situation. This isn't gambling; it's a calculated decision based on research and judgment, much like trading stocks or futures.
I also want to stress that event contracts shouldn't be labeled as "gaming." They serve legitimate economic purposes, like price discovery and risk management. Classifying them as gambling, as discussed in Questions 15-22 of your ANPR, ignores the real utility they offer to individuals and businesses. I hedge real risks with these contracts, and I'm not alone. Farmers, importers, and small business owners can use them to protect against policy shifts or economic uncertainty. This is serious financial strategy, not a game.
I'm also concerned that over-regulating or banning these markets would push activity offshore to unregulated platforms, which is far riskier for everyone. The US should be a leader in financial innovation, not cede that role to other countries. Regulated markets like Kalshi, operating under CFTC oversight, are the safer option. Plus, the CFTC already has strong tools to tackle manipulation and insider trading, as mentioned in Questions 1-6 and 29-32. I've seen how these safeguards work in other derivatives markets. There's no need for broad bans; just enforce the rules you already have.
I urge you to consider the benefits of prediction markets for ordinary traders like me. In response to Questions 7-14 on public interest, I believe the balance should tilt toward innovation and access while protecting consumers through targeted oversight, not categorical restrictions. Please support a regulatory framework that allows legal, regulated prediction markets to thrive and keeps the US at the forefront of financial innovation.
Thank you for considering my perspective.
Sincerely,
Isa Bre
