Comment Text:
Dear Chairman and Commissioners,
My name is Lee Neher, and Im a policy and government professional from Louisiana. Im writing to express my support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). Ive used prediction markets a few times myself, and I believe they offer unique value to individuals like me and to society at large, especially when it comes to understanding complex public events.
As someone who works in policy, Ive seen firsthand how hard it can be to get reliable information about elections or other significant events. Prediction markets have consistently produced forecasts that are more accurate than traditional polls or pundit opinions. Ive relied on these platforms to get a clearer picture of what might happen, whether its a national election or a key policy shift. This isnt just useful for traders; its valuable for anyone trying to make sense of the world. Beyond that, I value the freedom to participate in legal, regulated markets. These platforms democratize access to information, and I think its critical that regular people like me arent shut out.
I want to address a few specific concerns raised in your ANPR. Regarding Questions 15-22 on listed activities, I strongly believe event contracts should not be classified as gaming. They serve real economic purposes, like price discovery and hedging against uncertainty. Trading on these markets requires research and judgment, much like trading stocks or commodities. Calling it gambling misses the point of its utility. On Questions 7-14 about public interest, Id argue that regulated markets, like Kalshi operating under CFTC oversight, are far safer than unregulated offshore platforms. Banning or over-restricting prediction markets wont stop the activity; itll just push it to less safe venues outside U.S. jurisdiction. The U.S. should lead in financial innovation, not cede that ground to other countries.
As for Questions 29-32 on inside information, I believe informed trading actually improves price discovery and benefits everyone in the market. Existing laws already prohibit insider trading by federal employees and others with nonpublic information, and the CFTC has tools to tackle manipulation. The answer isnt broad bans but targeted enforcement of those rules. Proportionate regulation, addressing specific risks rather than whole categories of contracts, is the right path forward.
I urge the CFTC to support the growth of prediction markets with fair, balanced rules that protect consumers without stifling innovation. Lets keep these markets accessible, regulated, and in the U.S. where they can be properly overseen.
Thank you for considering my input.
Sincerely,
Lee Neher
