Comment Text:
Dear Chairman and Commissioners,
My name is Bradley Bowman, and I'm just an average citizen from North Carolina trying to make a living on my own terms. I don't have a fancy degree in business, and I'm not looking to work in a 100-degree factory if I can help it. I'm writing to you about the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) because I've found something that works for me. I actively trade on regulated prediction markets like Kalshi, and I believe these markets are valuable, not just for me but for society. I want to see them regulated properly, not banned or overly restricted.
Prediction markets give me a way to use my life experience and personal knowledge to make investments, often with better returns than a lot of other options I've tried. It's only a small part of my investing, but I've consistently done well because it involves things I understand, like election outcomes or economic events that affect my day-to-day life. To me, this isn't much different from day trading stocks. It takes research and judgment, not luck. So when I hear talk of classifying event contracts as "gaming," I don't see it that way. These contracts serve real purposes, like hedging risks or discovering better information. I'm not rolling dice; I'm making informed choices. I think your questions 15 to 22, about defining gaming versus legitimate markets, really get to the heart of this, and I urge you to see these contracts as economic tools, not gambling.
I also worry that banning or over-restricting these markets will push people like me to unregulated offshore platforms. I trust Kalshi because it's regulated by the CFTC, and I feel safer knowing there's oversight. If you make it too hard to trade here, folks will go elsewhere, to places with no consumer protections at all. Your questions 7 to 14 on balancing innovation and protection hit this point, and I think regulation, not prohibition, is the way to keep people safe.
Another thing that matters to me is the US staying ahead in financial innovation. We shouldn't let other countries take the lead on something this useful. My understanding is that prediction markets often give better forecasts than polls for things like elections, and that helps everyone, not just traders. Informed trading, even by people who know a lot, improves price discovery for all of us. On that note, regarding questions 29 to 32 about inside information, I believe the CFTC already has tools to stop insider trading or manipulation. Adapt those instead of broad bans that punish regular folks like me.
That's not to say there isn't risk. There will always be some people who will try to game the system, no matter what it is. But the answer isn't shutting down prediction markets. It's targeted rules to address specific problems. Please support proportionate regulation that lets everyday citizens like me participate in legal, regulated markets without pushing activity offshore, where nothing will stop those who will try to game the system.
Thank you for considering my thoughts.
Sincerely,
Bradley Bowman
