Comment Text:
Dear Chairman and Commissioners,
My name is Michael Kapustinsky, and I’m a healthcare professional from Pennsylvania. In addition to my work in healthcare, I am a full-time weather trader on prediction markets like Kalshi and Polymarket. Trading event contracts is not just a hobby for me; it’s a critical part of my financial stability and professional life. I’m writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for proportionate regulation of these markets, rather than bans or overly restrictive rules.
As someone who trades weather-related event contracts daily, I rely on prediction markets to hedge risks that directly impact my livelihood. Weather events affect everything from healthcare delivery to personal finances, and these markets allow me to make informed decisions based on aggregated data that’s often more accurate than traditional forecasts. This isn’t gambling—it’s a legitimate economic activity that requires research, analysis, and real-world judgment, much like trading stocks or commodities. I urge the CFTC, particularly in response to Questions 15-22 on listed activities, to recognize that event contracts serve vital purposes like price discovery and risk management, and should not be misclassified as “gaming.”
I also value my freedom to participate in legal, regulated markets. Prediction markets democratize access to information and financial tools, allowing everyday people like me to engage with events that affect our lives. Banning or over-restricting these markets, as discussed in Questions 7-14 on public interest, would not eliminate demand—it would simply push activity to unregulated offshore platforms where there are no consumer protections. I’ve seen firsthand how platforms like Kalshi, operating under CFTC oversight, provide a safe and transparent environment. Driving traders like me to less secure venues would be counterproductive and harmful.
I’m not blind to the concerns about manipulation or insider trading, as raised in Questions 29-32. But these issues are already addressed by existing laws and CFTC enforcement powers. Punishing law-abiding traders by restricting access to these markets is not the answer—enforcing current rules against bad actors is. As a healthcare professional, I know the importance of addressing root causes rather than applying blanket restrictions that hurt everyone.
Prediction markets are a vital tool for me, both professionally and financially. They provide unique insights and hedging opportunities that I can’t get elsewhere. I respectfully ask the CFTC to craft regulations that protect consumers while preserving access to these innovative markets. Please ensure that event contracts are treated as the legitimate financial instruments they are, and avoid policies that would drive activity offshore or exclude everyday Americans like me from participating.
Thank you for considering my perspective.
Sincerely,
Michael Kapustinsky