Comment Text:
Dear Chairman and Commissioners,
My name is Patrick Nolan, and I'm just a regular citizen from Pennsylvania writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been trading on platforms like Kalshi and Polymarket for a while now, and I strongly support the idea of well-regulated prediction markets in the United States. I think they offer real value to people like me, and I hope the CFTC will create rules that let these markets thrive without over-restricting them.
I got into prediction markets because I wanted a way to hedge against uncertainties that affect my personal finances. For example, I've used these platforms to offset risks tied to inflation data releases that impact my budget for groceries and rent. It's not gambling to me; it's a practical tool. I do my homework, follow the news, and make informed decisions, just like I would with any other investment. Beyond my own use, I see how these markets help others too. Small businesses can hedge against policy changes or economic shifts, and the prices often give better insights than polls or pundits. That kind of information benefits everyone.
What worries me is the idea of pushing these markets offshore by over-regulating them here. I've traded on both regulated platforms like Kalshi and unregulated ones like Polymarket. The difference is night and day. On a regulated platform, I feel safer knowing there's oversight and rules in place. Offshore, it's a free-for-all with no protections if something goes wrong. If the CFTC cracks down too hard, people won't stop trading; they'll just go to riskier, unregulated sites. I think the U.S. should lead the way in financial innovation by setting smart, balanced rules instead of letting other countries take over this space.
Regarding some of the specific questions in the ANPR, I want to address Question 7 on balancing innovation and consumer protection. I believe the CFTC can do both by focusing on targeted regulations, like enforcing existing laws against manipulation and insider trading, rather than broad bans on certain contracts. Also, on Question 23 about procedural aspects, I think public interest determinations should happen on a case-by-case basis, not with blanket categories that might unfairly limit legitimate markets.
I understand there are concerns about manipulation or bad actors, but the answer isn't to shut these markets down. The CFTC already has tools to tackle fraud and insider trading in other markets. Use those same tools here. Don't punish regular folks like me who use these platforms responsibly.
In closing, I urge the CFTC to support proportionate regulation of prediction markets. Let us participate in legal, regulated spaces where we can hedge real risks and access valuable information. Please don't over-restrict or ban these markets; instead, craft rules that protect consumers while fostering innovation right here in the U.S.
Thank you for considering my input.
Sincerely,
Patrick Nolan
