Comment Text:
Dear Chairman and Commissioners,
My name is Niall Kehoe, and I'm a senior at Stanford University. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, I've seen firsthand the value these markets bring, and I believe the CFTC has a chance to craft rules that protect consumers while fostering innovation.
I rely on prediction markets for accurate forecasting of elections and other public events. In my experience, the probabilities on these platforms consistently outperform polls and pundits. As a tech professional, I value data-driven insights, and the price discovery mechanism on Kalshi cuts through the noise of traditional media and so-called expert analysis. This isn't just useful for traders like me; the transparency of public order books provides better information for everyone, from journalists to policymakers. I see this as a positive externality that benefits society as a whole.
I also appreciate the freedom to participate in a legal, regulated market. Kalshi offers a venue to monetize my opinions, much like any traditional financial exchange. Unlike sports books that quickly limit successful bettors, prediction markets let informed traders contribute to more accurate pricing. This isn't gambling; it takes research and judgment. Banning or over-restricting these markets would be a mistake. It wouldn't stop trading; it would just push activity to unregulated offshore platforms where there are no consumer protections. I'd much rather trade on a CFTC-registered market with oversight than take my chances in a less safe environment.
I'm also concerned about U.S. competitiveness in financial innovation. Tech moves fast, and if we over-regulate or shut down prediction markets, other countries will step in. We should be leading on this, not ceding ground. On specific questions in the ANPR, like those in Topic B on public interest (Questions 7-14), I urge you to weigh the benefits of innovation and price discovery against risks. And on Topic E regarding inside information (Questions 29-32), I believe informed trading generally improves market accuracy and benefits all participants, as long as existing laws against insider trading are enforced.
I'm asking you to support well-regulated prediction markets with targeted rules that address specific risks without broad bans. Keep platforms like Kalshi accessible to everyday traders like me, and ensure the U.S. remains a leader in financial technology.
Thank you for considering my input.
Sincerely,
Niall Kehoe
