Comment Text:
Dear Chairman and Commissioners,
My name is Edward Mun, and I'm a finance professional based in Texas. I've been working in finance for over a decade, analyzing markets and managing risk for myself and my clients. Im 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 actively trade on platforms like Kalshi, and Ive seen firsthand how valuable these markets are for forecasting, hedging, and decision-making.
Prediction markets arent just a niche hobby for me. They provide information thats often more accurate than polls or pundit opinions. For instance, during the last election cycle, I relied on Kalshis election outcome contracts to gauge probabilities that no survey could match. Those prices helped me advise clients on potential tax policy shifts that could affect their portfolios. This isnt gambling. Its research and judgment, much like trading stocks or futures. The aggregated wisdom of many traders, even small ones like me, creates better data for everyone, from individuals to policymakers. I believe this ties directly to your questions on price discovery and public interest (Questions 7-9), and I urge the CFTC to recognize the societal value of these markets.
I also use prediction markets to hedge personal and business risks. A contract on a Federal Reserve rate decision, for example, helps me plan around mortgage or loan costs. This hedging utility isnt theoretical. Its practical for regular people and small businesses, not just big institutions. On that note, Im concerned about the alternative if these markets are banned or over-restricted. If platforms like Kalshi cant operate under CFTC oversight, activity will just move to unregulated offshore sites. Ive seen offshore platforms in my line of work, and they lack the transparency and consumer protections of a regulated designated contract market. Addressing your questions on consumer protection (Questions 10-11), I think regulation is the answer, not prohibition.
Lastly, I want to touch on informed trading, related to Questions 29-31. I believe traders with good information improve price accuracy for everyone. Banning markets to prevent insider trading punishes honest participants like me. The CFTC already has tools to tackle manipulation and insider trading in other derivatives markets. Use those tools here instead of broad restrictions.
Prediction markets are a powerful tool for forecasting and risk management. Theyve helped me make better financial decisions, and they can do the same for others if kept accessible under fair rules. I respectfully ask the CFTC to support proportionate regulation that protects consumers without stifling innovation or pushing activity offshore.
Sincerely,
Edward Mun
