Comment Text:
Dear Chairman and Commissioners,
My name is Benjamin Criteser, and I'm a trader and investor based in New York. I'm writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been actively trading on platforms like Kalshi, and I can honestly say it's been exciting to participate in this new economic space. It's not just fun; it's genuinely useful for someone like me whos always looking for ways to manage financial risks.
Prediction markets aren't gambling, despite what some might claim. They serve real economic purposes, like hedging risks that affect my personal finances and investments. For example, I've used Kalshi to hedge against uncertainties like election outcomes that could impact tax policies or market conditions relevant to my portfolio. This isn't a game; it takes research and judgment, much like trading stocks or commodities. Classifying event contracts as "gaming" undercuts their legitimate value, and I urge the CFTC to recognize this in response to Questions 15-22 on listed activities.
I also believe these markets improve price discovery, which benefits everyone, not just traders. Informed trading, as discussed in Questions 29-32 on inside information, helps make prices more accurate. Academic research backs this up, showing prediction markets often outperform polls and pundits. The data transparency is a public good. Plus, the CFTC already has solid tools to tackle manipulation and insider trading. Theres no need for broad bans when targeted enforcement can address bad actors without punishing the rest of us.
I'm worried that over-restricting or banning these markets will just push activity offshore to unregulated platforms, where there's less oversight and more risk. The US should be leading in financial innovation, not handing that advantage to other countries. I hope the CFTC considers this under Questions 7-14 on public interest. Proportionate regulation, not categorical prohibitions, is the way to go. Let's keep these markets accessible to regular people like me who want to participate in legal, regulated spaces.
I also use prediction markets to hedge real risks, and I know businesses do too. Whether it's a policy change or an economic indicator, these contracts help manage uncertainty. Banning them would strip away a valuable tool. I encourage the CFTC to focus on specific risks with targeted rules, as explored in Questions 1-6 on core principles, rather than sweeping restrictions.
Thank you for considering my input. I strongly support the development of proportionate regulations for prediction markets that protect consumers while preserving access and innovation. Please don't let over-regulation shut down this promising space.
Sincerely,
Benjamin Criteser
