Comment Text:
Dear Chairman and Commissioners,
My name is Justin Sevigny, and I'm a trader and investor from Michigan. I make my living as a professional sports bettor, though I've been kicked off most traditional sportsbooks due to their restrictions. Now, I rely on exchanges like prediction markets to do my job. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, published in 91 FR 12516, to express my strong support for well-regulated prediction markets. I believe they provide unique value and should not be overly restricted or banned.
As someone who trades actively on platforms like Kalshi, I can tell you firsthand that these markets are not gambling. They require research, analysis, and real-world judgment, much like trading stocks or commodities. I use prediction markets to make informed decisions based on data and trends, and the prices often reveal insights you can't get from polls or news. This isn't just useful for me; it's valuable for anyone trying to understand what's likely to happen in politics, economics, or even weather events. Calling this "gaming" feels like a misstep when it's clearly a form of investing with real economic purpose.
What concerns me most is the idea of shutting down or over-regulating these markets. I've seen what happens when legal, regulated options disappear. People like me don't stop trading; we just get pushed to unregulated offshore platforms that offer no protections. Kalshi, as a CFTC-registered market, gives me a safe, transparent place to operate. I know my trades are monitored, and there's accountability if something goes wrong. Offshore sites? No such luck. If the CFTC clamps down too hard, you're not protecting consumers; you're driving us to riskier places.
I also want to address a couple of specific questions from your ANPR. On Question 7, about balancing innovation and consumer protection, I think regulated markets like Kalshi already strike that balance. They allow innovation while keeping guardrails in place. And on Question 15, regarding whether event contracts are gaming, I strongly believe they aren't. These contracts let people hedge real risks or gain unique information, which is far from a game of chance.
I get that there are concerns about manipulation or insider trading. But those are already illegal, and the CFTC has the tools to enforce against bad actors. Banning or over-restricting prediction markets punishes everyone for the actions of a few. Instead, I urge you to focus on proportionate rules that target specific risks without killing off a valuable tool for people like me.
Thank you for considering my perspective. I strongly support the continued operation of regulated prediction markets under fair, balanced oversight. Please don't let heavy-handed restrictions push traders like me into unsafe, unregulated spaces.
Sincerely,
Justin Sevigny
