Comment Text:
Dear Chairman and Commissioners,
My name is Michael Moorefield, and I'm a trader and investor from Alabama. 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 your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to people like me and to society as a whole, and I urge you to regulate them proportionately rather than imposing overly restrictive rules or outright bans.
As a trader, Ive seen firsthand how prediction markets produce forecasts that are often more accurate than polls or pundits. Whether its an election outcome or a major public event, the prices on these platforms cut through the noise and give me a clearer picture of whats likely to happen. This isnt just helpful for my trading decisions; its valuable information for anyone paying attention, from regular folks to policymakers. I also value the freedom to participate in legal, regulated markets like Kalshi. These platforms are transparent and safe, unlike unregulated offshore alternatives where theres no oversight. If the CFTC over-restricts or bans these markets, I worry activity will just get pushed to those riskier venues. Thats not protecting consumers; its the opposite.
I want to address a few specific concerns from your ANPR. On the question of whether event contracts are gaming (Questions 15-22), I strongly believe theyre not. Trading on prediction markets requires research and judgment about real-world events, much like trading stocks or commodities. These contracts serve legitimate economic purposes, like price discovery and hedging against uncertainty. Classifying them as gambling misses the point. On public interest and innovation (Questions 7-14), I think the U.S. should be a leader in financial innovation. If we stifle prediction markets with heavy-handed rules, were just handing the advantage to other countries. And regarding insider trading or manipulation (Questions 29-32), I believe the CFTC already has solid tools to address these risks. Informed trading actually improves price discovery, benefiting everyone in the market. Punishing the whole industry for a few bad actors isnt the answer; targeted enforcement is.
Im not blind to the need for consumer protection, but regulation should focus on specific risks without killing the market. Banning broad categories of contracts or over-restricting access doesnt solve problems; it creates new ones by driving traders like me to less safe platforms. I trust the CFTC can strike a balance that keeps these markets fair and open.
Thank you for considering my perspective. I urge you to support proportionate regulation of prediction markets and avoid bans or overly restrictive rules that would harm innovation and consumer choice.
Sincerely,
Michael Moorefield
