Comment Text:
Dear Chairman and Commissioners,
My name is Will Dan, and I'm a finance professional based in Maryland. I'm 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 proportionate regulation of prediction markets. I believe they provide unique value to individuals like me and to society as a whole, and I urge the CFTC to craft rules that foster their growth while addressing legitimate risks.
As someone who works in finance, I rely on accurate data to make informed decisions. Prediction markets have consistently provided forecasts on elections and public events that outshine traditional polls or punditry. I've used these platforms to gain insights into political outcomes that could impact markets I work with, and the aggregated wisdom of these trades often reveals trends I can't find elsewhere. Beyond that, I use prediction markets to hedge personal and business financial risks. For instance, trading on contracts tied to economic indicators or policy decisions helps me offset uncertainties that could affect my investments or clients' portfolios. This isn't gambling. It takes research and judgment, much like trading stocks or commodities.
I'm concerned that banning or over-restricting these markets, as some have suggested, would simply push activity to unregulated offshore platforms. I've seen firsthand how accessible and transparent a regulated market like Kalshi is, with clear rules and oversight. If the CFTC clamps down too hard, people like me won't stop seeking these tools; we'll just end up on less safe, foreign sites with no consumer protections. That seems like the opposite of what regulation should achieve. I also strongly believe event contracts shouldn't be classified as gaming. They serve real economic purposes, like hedging and price discovery, which are core to financial markets. Labeling them as gambling ignores their utility and risks stifling innovation.
In response to some of the specific questions in the ANPR, particularly Questions 7 and 8 under Public Interest, I think the CFTC should prioritize balancing innovation with consumer protection by focusing on transparency and enforcement of existing anti-manipulation laws rather than broad prohibitions. And regarding Questions 15 and 16 on Listed Activities, I urge you to define gaming narrowly and recognize the legitimate economic functions of event contracts, avoiding blanket restrictions that could harm users like me.
I know there are valid concerns about insider trading or manipulation, but the answer isn't to shut down prediction markets. Those behaviors are already illegal, and the CFTC has the authority to enforce against bad actors. Punishing the entire market for a few bad apples would be unfair and counterproductive. Please support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules.
Thank you for considering my input.
Sincerely,
Will Dan
