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Comment for Proposed Rule 91 FR 12516

  • From: Lecrack Ledown
    Organization(s):

    Comment No: 117457
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Lecrack Ledown, and I'm a healthcare professional from Texas. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the idea of well-regulated prediction markets. Ive got to be honest, though. I think theres a lot of degeneracy out there in some corners of this space, and the CFTC needs to crack down on bad actors. But shutting down the whole market isnt the answer. These markets serve a real purpose, and I want to explain why I think theyre valuable, both to me and to society.


    As someone working in healthcare, I deal with uncertainty all the time. Policy changes, like shifts in healthcare regulations or funding, can hit my field hard. Ive used prediction markets to hedge against some of that uncertainty. For instance, trading on contracts tied to election outcomes helps me gauge potential impacts on my profession and plan accordingly. Its not just me, either. Businesses, farmers, and regular folks can use these markets to protect against risks, whether its a tariff change affecting an importer or a weather event messing up travel plans. This isnt gambling. Its about research and judgment, just like trading stocks. I put in the time to read up on issues before placing a trade, and Im not just flipping a coin.


    I know there are concerns about manipulation or insider trading, and I get it. Theres some shady stuff out there, and Im all for cracking down on that degeneracy. But the CFTC already has tools to handle fraud and manipulation in other markets. Use those same tools here. Banning prediction markets or over-restricting them punishes people like me who use them responsibly. Its like closing a hospital because a few doctors mess up. And if you push these markets offshore by overregulating, youll just make things less safe for everyone.


    Id like to address a couple of specific questions from the ANPR. On Question 15, about defining gaming versus legitimate markets, I firmly believe event contracts arent gambling when theyre tied to real economic outcomes. Theyre tools for hedging and price discovery. And on Question 7, about balancing innovation and consumer protection, I think the answer is targeted rules, not broad bans. Focus on the bad actors, not the whole system.


    I urge the CFTC to support proportionate regulation of prediction markets. Dont let a few bad apples spoil a tool that helps people manage real risks. Keep these markets accessible, safe, and under your oversight, so folks like me can continue to use them responsibly.


    Sincerely,

    Lecrack Ledown

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