Comment Text:
Dear Chairman and Commissioners,
My name is Jordan Sherman, and I'm a student from Utah with a strong interest in economics and public policy. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my support for well-regulated prediction markets. As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide valuable insights and opportunities, and I believe the CFTC should regulate them proportionately rather than impose overly restrictive rules.
Prediction markets have become a key tool for me as a student studying political and economic trends. I trade on Kalshi to follow election outcomes and other public events, and Ive found the prices often reflect a clearer picture than polls or media speculation. This isnt just useful for traders like me; its a public good when accurate forecasts help everyone understand what might happen next. I also value the freedom to participate in these legal, regulated markets. Banning or over-restricting them would likely push activity to unregulated offshore platforms, which are far less safe and lack oversight. Id much rather trade on a CFTC-regulated platform like Kalshi, where there are clear rules and protections in place.
Beyond forecasting, Ive come to appreciate how prediction markets let individuals and businesses hedge real risks. For example, a small business owner might use these markets to protect against policy changes tied to an election outcome. As a student, I dont have big financial stakes, but I can see how this matters to others. Also, I believe informed trading improves price discovery, which benefits all participants. If someone has unique insight and trades on it, that helps the market reflect reality better. Addressing insider trading concerns shouldnt mean shutting down entire markets; it means enforcing existing laws, which the CFTC already has the power to do.
I want to touch on a couple of specific questions from the ANPR. On Question 7, regarding balancing innovation and consumer protection, I think regulated markets strike that balance by encouraging participation while having safeguards against manipulation. And on Question 29, about informed traders and price discovery, I strongly believe their participation makes markets more accurate, as long as its within legal bounds.
As someone who also cares about academic research, I hope the CFTC considers how prediction markets provide transparent data for studying human behavior and forecasting. Over-regulating them could limit access to this resource. I urge you to support proportionate regulation that addresses specific risks without banning or overly restricting these valuable tools. Thank you for considering my perspective.
Sincerely,
Jordan Sherman
