Comment Text:
Dear Chairman and Commissioners,
My name is Jonathan Stirman, and I'm a trader and investor based in Alaska. I've been actively trading on prediction markets like Kalshi and Polymarket 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 provide unique value to people like me, as well as society at large, and I urge you to adopt proportionate regulations rather than overly restrictive rules or bans.
As someone who trades regularly, I've seen firsthand how prediction markets offer information you can't get anywhere else. Their forecasts on elections and public events often beat polls and pundits by a wide margin. I rely on this data to make smarter decisions, not just in trading but in understanding the world. This isn't gambling, it's a skill based on research and judgment, much like trading stocks or commodities. Labeling event contracts as "gaming" ignores their real economic purpose, whether it's price discovery or hedging risks. For example, I've used these markets to hedge personal financial risks tied to economic policy changes, like interest rate decisions that affect my investments. Small businesses and individuals across Alaska could do the same if given fair access.
I'm also concerned about what happens if the CFTC over-restricts these markets. Regulated platforms like Kalshi are transparent and safe, with oversight to prevent manipulation or insider trading. The CFTC already has strong tools to handle those risks, and they should use them rather than impose broad bans. If you push too hard with restrictions, activity will just move to unregulated offshore platforms where there's no consumer protection at all. I've traded on some of those sites, and the difference in safety and reliability is night and day. The US should be leading in financial innovation, not ceding ground to other countries by driving markets away.
On specific questions in the ANPR, I want to address a few points. Regarding Questions 7-14 on public interest, I believe prediction markets balance innovation and consumer protection when regulated properly. They improve price discovery and help everyone, not just traders, make better decisions. On Questions 15-22 about listed activities, event contracts shouldn't be classified as gaming; they serve legitimate purposes like hedging and forecasting. And on Questions 29-32 about inside information, I think informed trading actually helps price discovery, making markets more accurate for all participants. Existing laws already ban insider trading by federal officials, so the focus should be enforcement, not shutting down markets.
I ask that the CFTC adopt targeted, proportionate rules that address specific risks without punishing the majority of honest traders. Prediction markets are a powerful tool for forecasting, hedging, and democratizing information. Let's keep them accessible and safe under US oversight.
Sincerely,
Jonathan Stirman
