Comment Text:
Dear Chairman and Commissioners,
My name is Jacob Dooley, and I'm a policy professional from Wisconsin. Im writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the CFTC crafting proportionate regulations that allow prediction markets to thrive in the United States.
As someone who works in policy and government, I see firsthand how hard it is to get reliable, real-time information for decision-making. Prediction markets have been a game-changer for me. The prices on platforms like Kalshi often cut through the noise of polls and pundits, offering insights I cant find elsewhere. This isnt just useful for traders like me; its valuable for the public, media, and even policymakers who need better data to understand trends. I believe this ties directly to your questions on price discovery in the Public Interest section (Questions 7-14). These markets aggregate information efficiently, and that benefits everyone.
I also care deeply about the freedom to participate in legal, regulated markets. Banning or over-restricting prediction markets wont stop people from trading; itll just push activity to unregulated offshore platforms where theres no oversight. Id much rather trade on a CFTC-regulated platform like Kalshi, where I know there are safeguards, than take my chances with some sketchy foreign site. This relates to your questions on balancing innovation and consumer protection (also in Questions 7-14). Regulation should keep markets safe, not drive them underground.
On a broader level, Im worried about the U.S. losing ground in financial innovation. If we over-regulate or ban prediction markets, were handing leadership to other countries who are more willing to embrace new ideas. As a policy professional, I think the U.S. should be setting the standard for how these markets operate, not playing catch-up. This speaks to some of your Classification and Costs-Benefits questions (Questions 33-40) about the broader impact of regulation.
Lastly, I want to address concerns about insider trading or manipulation, which I know are on your mind (Questions 29-32 on Inside Information). I believe informed trading actually improves price discovery; it makes the markets predictions sharper and more useful. Bad actors are already covered by existing laws against manipulation and insider trading. The CFTC has the tools to enforce those rules without shutting down entire markets. Lets not punish everyone for the actions of a few.
I urge the CFTC to support well-regulated prediction markets with clear, fair rules that protect participants while allowing innovation. Please dont impose bans or overly restrictive policies that would harm legitimate traders and cede U.S. leadership in this space. Thank you for considering my input.
Sincerely,
Jacob Dooley
