Comment Text:
Dear Chairman and Commissioners,
My name is Brady Tosh, and I'm a trader and investor based in Wyoming. I've been actively trading on prediction markets like Kalshi for a while now, and I'm 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 offer unique value, and I urge the CFTC to craft rules that protect participants while allowing this innovative space to thrive.
As someone who trades regularly, I've seen firsthand how prediction markets provide insights you just can't get from polls or pundits. I've used Kalshi to trade on election outcomes and economic indicators, and the prices often reflect a clearer picture of what's likely to happen than anything I hear on TV or read online. This isn't just useful for traders like me. It helps everyone, from small business owners to regular folks, better understand the world. I think that's worth protecting.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi operate under CFTC oversight, which gives me confidence that there are rules in place to prevent manipulation and fraud. If we over-restrict or ban these markets, people won't stop trading. They'll just move to unregulated offshore platforms where theres no protection at all. I've looked at some of those sites, and theyre a mess. Keeping activity on regulated exchanges is safer for everyone.
Another thing that concerns me is the risk of the US falling behind. Prediction markets are a cutting-edge financial tool, and the US should be leading the way in this kind of innovation. If we clamp down too hard, other countries will step in and take the lead. I've traded in other markets where the US sets the standard, and I'd hate to see us lose ground here.
I'm particularly interested in a few of the questions you raised in the ANPR. On Question 7, about balancing innovation and consumer protection, I think the CFTC can do both by focusing on strong oversight of exchanges rather than broad bans. For Question 14, comparing prediction markets to other tools, Id argue theyre unique in how they aggregate information and shouldn't be treated like gambling. And on Question 33, about classification, I believe event contracts fit as derivatives and should be regulated accordingly, not pushed out of existence.
I know there are concerns about things like insider trading or manipulation, and those are valid. But the CFTC already has tools to address bad actors in other markets, and I believe those can be applied here without shutting down the whole industry. Let's not punish honest traders for the actions of a few.
I respectfully ask the CFTC to support proportionate regulation of prediction markets. Please allow platforms like Kalshi to operate under clear, fair rules that protect participants and encourage innovation. Thank you for considering my input.
Sincerely,
Brady Tosh
