Comment Text:
Dear Chairman and Commissioners,
My name is Finis Cole, and I'm a trader and investor based in Tennessee. I've been actively trading on prediction markets like Kalshi for a while now, and 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 believe these markets provide unique value to people like me, as well as to the broader public, and I urge the CFTC to craft rules that encourage innovation while addressing real risks.
As a trader, Ive seen firsthand how prediction markets offer information you cant get anywhere else. The prices reflect a collective judgment thats often more accurate than polls or pundits. Ive used this data to make better decisions, not just in trading but in understanding what might happen with elections or economic shifts. This isnt just helpful for me; its valuable for anyone making decisions, from business owners to policymakers. I think the CFTC should recognize this public benefit when considering regulations, especially in response to Questions 7 and 8 about balancing innovation with consumer protection.
I also want to push back on the idea that event contracts are gambling. Thats not how I see it at all. Trading on these markets takes research, analysis, and real-world judgment, just like trading stocks or commodities. Im not rolling dice; Im making informed bets on outcomes that matter to my financial planning. Hedging against policy changes or economic events has real economic purpose. I hope the CFTC will address this distinction when defining gaming under Questions 15 and 16.
What really drives me to write, though, is my concern about U.S. competitiveness. Weve got a chance to lead the world in financial innovation with prediction markets. Platforms like Kalshi, operating under CFTC oversight, show we can do this responsibly. But if we over-restrict or ban these markets, were just handing the future to other countries with looser rules or offshore platforms with no oversight. Id rather see the U.S. set the standard. This ties directly to Questions 33 and 34 on classification and regulatory costs. Please dont burden small entities or innovators with rules that push this industry overseas.
I get that there are concerns about manipulation or insider trading. Those are real issues. But the CFTC already has tools to tackle fraud and abuse in other markets, and those can work here too. Banning or over-restricting prediction markets punishes honest traders like me instead of targeting bad actors. Lets focus on enforcement, not prohibition.
I strongly urge the CFTC to support proportionate regulation that allows prediction markets to grow while addressing specific risks. Dont let the U.S. fall behind in this space. Thank you for considering my input.
Sincerely,
Finis Cole
