Comment Text:
Dear Chairman and Commissioners,
My name is Bridge Dudley, and I'm a trader and investor based in New York. I run a consumer sports research platform that helps users make better predictions, and I've been actively trading on prediction markets like Kalshi for some time now. I'm writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to individuals like me and to society as a whole, and I urge the CFTC to craft rules that protect consumers without stifling innovation.
Through my platform, I've seen firsthand how prediction markets offer unique benefits. Nine out of ten times, Kalshi sports contracts are more cost-effective than traditional sportsbook offerings, and our users often report more profitable outcomes after switching to Kalshi. This isn't gambling in the way some might think. Trading on these platforms requires research, analysis, and real-world judgment, much like trading stocks or commodities. Classifying event contracts as "gaming," as discussed in Questions 15-22, overlooks their legitimate economic purpose, whether it's price discovery or hedging risks tied to real events.
I also want to stress that regulated markets like Kalshi are far safer than the unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, you're not stopping the activity, you're just pushing it to less transparent, riskier venues. I've seen how offshore platforms operate with little oversight, and that's not where we want American consumers. The US has a chance to lead in financial innovation here, not cede ground to other countries. Keeping these markets regulated under the CFTC ensures consumer protection while fostering growth, a balance I think Questions 7-14 on public interest get at.
Another point I care about is the forecasting power of prediction markets. Time and again, they've proven more accurate than polls or pundits in predicting outcomes, from elections to economic indicators. This information benefits everyone, not just traders. And on the topic of informed trading, raised in Questions 29-32, I believe it improves price discovery. When knowledgeable participants trade, the market prices reflect reality better, helping all of us make smarter decisions.
I know there are concerns about manipulation or insider trading, and those aren't trivial. But the CFTC already has tools to tackle bad actors, and banning entire markets to stop a few wrongdoers punishes the rest of us who play by the rules. Focus on enforcing existing laws rather than broad restrictions.
I'm asking the CFTC to support proportionate regulation that allows prediction markets to thrive under clear, fair rules. Don't let over-regulation drive innovation and consumer choice offshore. Thank you for considering my perspective as you shape this policy.
Sincerely,
Bridge Dudley
