Comment Text:
Dear Chairman and Commissioners,
My name is Jett Giesey, and I'm a student from Ohio writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi, and I believe these markets provide real value, both to me personally and to society at large. I'm concerned that overly restrictive regulations or outright bans could harm the benefits these markets offer, and I want to urge the CFTC to support proportionate regulation instead.
As a student, I don't have a huge budget, but prediction markets give me a way to engage with real-world events in a meaningful way. I research topics like election outcomes or economic indicators, and I place small trades based on what I learn. It's not gambling, not by a long shot. It takes time, effort, and judgment, much like investing in stocks. These event contracts help me hedge personal risks, like potential policy changes that could affect my student loans or future job market. I see this as a legitimate economic activity, not a game, and I believe the CFTC should recognize that distinction when considering questions like those in Topic Area C, specifically Question 15 about defining gaming versus legitimate markets.
I'm also worried about what happens if these markets get banned or over-regulated. I've seen unregulated offshore platforms out there, and they're far riskier than a CFTC-registered market like Kalshi. If the U.S. pushes this activity underground, people like me lose access to safe, transparent markets. We'll either stop participating or take bigger risks on less secure sites. That can't be the goal. I'd ask the CFTC to consider this when addressing questions under Topic Area B, like Question 7 on balancing innovation and consumer protection.
Another point I want to make is about informed trading. I know there are concerns about insider information, as raised in Topic Area E, like Question 29. But I think traders who are well-informed actually make the market better for everyone. Their trades improve price discovery, which means the predictions are more accurate. That benefits not just traders, but anyone who looks at these prices for insight, whether it's journalists, policymakers, or regular folks like me. The CFTC already has tools to tackle insider trading and manipulation. Use those, but don't punish all of us by restricting the market.
Prediction markets are a unique tool. They let people like me participate in a system thats fairer and more accessible than traditional finance. I hope the CFTC will craft rules that protect consumers without shutting down innovation or access. Please support proportionate regulation of prediction markets, and avoid bans or overly harsh restrictions that could drive activity offshore or limit their benefits.
Thank you for considering my input.
Sincerely,
Jett Giesey
