Comment Text:
Dear Chairman and Commissioners,
My name is Moogie Hong, and I'm a small business owner from California. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm relatively new to prediction markets, but I strongly support their development under fair and proportionate regulation. As someone who runs a business, I see real value in these markets for both myself and society, and Im concerned about the risks of over-restricting them.
Running a business means dealing with uncertainty every day, whether it's changes in regulations, election outcomes that impact taxes, or economic shifts that affect my costs. Prediction markets offer a unique way to get accurate information that I can't find in polls or news. They also provide a tool to hedge real financial risks tied to events beyond my control. For instance, if an election result could change a policy affecting my supply chain, having a way to offset that risk through a regulated platform like Kalshi would be a game-changer. This isn't gambling to me; it's a practical way to protect my livelihood, much like buying insurance or hedging with other financial tools.
I also believe these markets benefit everyone by improving public decision-making. The forecasts they produce often beat out pundits and surveys, giving better insights into elections and other major events. That kind of information should be accessible to regular people like me, not just big institutions. Plus, allowing everyday Americans to participate in legal, regulated markets feels fair and democratic. Its about freedom to engage in a system thats transparent and overseen by the CFTC.
Addressing some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I think the balance between innovation and consumer protection lies in regulation, not prohibition. Regulated platforms are far safer than unregulated offshore ones. If the CFTC bans or over-restricts prediction markets, activity will just move to less safe venues outside U.S. oversight. That hurts consumers more than it helps. On Topic Area A (Questions 1-6), I trust the CFTC already has strong tools to prevent manipulation and insider trading in other derivatives markets. Those same tools can work here without needing broad bans.
I also care about U.S. competitiveness. We should be leading in financial innovation, not pushing it away. Over-regulation risks losing that edge to other countries. So, my ask is simple: please support proportionate regulation of prediction markets. Focus on targeted rules to address specific risks, not blanket restrictions that punish honest participants and drive activity offshore.
Thank you for considering my perspective.
Sincerely,
Moogie Hong
