Comment Text:
Dear Chairman and Commissioners,
My name is Victorian Heidenreich, and I'm just an everyday citizen from Minnesota writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been trading on platforms like Kalshi for a while now, and I strongly support the idea of well-regulated prediction markets. I believe they offer real value, and I hope the CFTC will craft rules that allow people like me to keep participating in a safe, legal way.
I got into prediction markets because they give me insights I can't find anywhere else. Whether it's an election outcome that might affect my taxes or a Federal Reserve decision that could impact my mortgage rates, these markets help me make sense of the world and even hedge against uncertainties. This isn't gambling to me. It takes research and judgment, much like investing in stocks. Classifying event contracts as "gaming" feels wrong when they serve legitimate economic purposes like price discovery and risk management. I urge the CFTC to recognize this distinction when addressing questions like those in Topic Area C, specifically Question 15 about defining gaming versus legitimate markets.
I'm also worried about what happens if these markets get banned or over-restricted. I've seen unregulated offshore platforms out there, and they're far riskier than a regulated market like Kalshi. If the CFTC cracks down too hard, people won't stop trading; they'll just move to less safe venues where there's no oversight. On this point, I think Question 7 under Public Interest hits the nail on the head. Balancing innovation and consumer protection means keeping these markets legal and regulated here in the US, not pushing activity offshore. The US should be a leader in financial innovation, not cede that ground to other countries.
I know there are concerns about manipulation or insider trading, and I get that. But the CFTC already has strong tools to tackle those issues in other derivatives markets. Why not adapt those for event contracts instead of broad bans? I think Question 29 under Inside Information is relevant here. Informed traders can actually improve price accuracy, and bad actors can be dealt with using existing laws. Let's not punish everyone for the actions of a few.
In short, I'm asking the CFTC to support proportionate regulation that targets specific risks without shutting down entire markets. Keep platforms like Kalshi operating under clear, fair rules so everyday folks like me can participate safely. Don't let heavy-handed restrictions drive this innovation offshore. Thank you for considering my perspective.
Sincerely,
Victorian Heidenreich
