Comment Text:
I am 27 years old. I am unemployed. I live in Delaware. I am not a lawyer, a financial professional, or a lobbyist. I am submitting this comment because the Commission asked for public input, and I have something to say.
Kalshi should be banned. What follows is why, addressed to the specific questions the Commission raised.
On Whether These Contracts Serve the Public Interest (Questions 7–11)
The CEA exists to serve markets that enable price discovery and commercial risk management. Kalshi's contracts do neither for ordinary people. Nobody using Kalshi to bet on whether a senator gets indicted or whether inflation hits a specific number has a commercial exposure to that outcome they are trying to hedge. They are speculating on binary events for money. That is gambling. The public interest the CEA was written to protect has nothing to do with that activity.
The Commission asks how event contracts contribute to "managing and assuming price risks" under CEA section 3(a). For retail participants on Kalshi, they do not. At all. The Commission should stop pretending otherwise.
On Gaming (Question 19)
The Commission asks whether prediction market contracts constitute "gaming" under CEA section 5c(c)(5)(C) and what factors define that term.
Here is the simplest possible test: if you replaced every Kalshi contract with an equivalent proposition bet at a sportsbook, would anyone notice a difference? The answer is no. Binary outcome. Fixed odds. Money at risk. No underlying commercial exposure. That is gaming by any honest definition — statutory, clinical, or common sense.
The Commission also asks whether it should consider that prediction market participants tend to be younger than other derivatives traders. It should — and it should treat it as disqualifying. Young people are the most vulnerable population for gambling disorder. Kalshi markets to them relentlessly on social media. The Commission licensing that activity without a single responsible gambling requirement is indefensible.
On Unlawful Activity Under State Law (Question 16)
The Commission asks how to handle contracts that are unlawful under some state laws but not others.
Delaware — my state — has a regulated gambling framework. Licensed operators here must meet age verification standards, fund addiction treatment, and enforce limits. Kalshi meets none of these requirements because its CFTC registration preempts state law. That means a Delaware resident can access an unregulated gambling product that would be illegal if offered by anyone without a federal commodity exchange license.
That is not a jurisdictional nuance to be studied. That is a loophole that is actively harming people in my state right now. The Commission should close it.
On Inside Information and Manipulation (Questions 29–32)
The Commission asks whether prediction markets are susceptible to manipulation by people with asymmetric information advantages.
Yes. Obviously. A contract on whether a specific piece of legislation passes is a direct financial incentive for congressional staffers, lobbyists, and political operatives — people who know things the public does not — to trade for personal gain. The Commission acknowledges this risk and has brought zero enforcement actions. That is not a regulatory framework. That is an honor system applied to people with strong financial incentives to cheat.
The Commission further asks about cross-market manipulation — whether prediction market positions could be used to influence other markets or vice versa. This risk is real and growing as these platforms scale. A large coordinated position in a political prediction market can move prices that journalists and the public treat as probability indicators, which in turn can move securities markets. The Commission has no surveillance infrastructure capable of detecting this. That alone should be disqualifying.
On Procedural Reform and Self-Certification (Questions 23–28)
The Commission asks about the listing process and whether self-certification is adequate.
It is not. Kalshi listed approximately 1,600 contracts in 2025 through a process requiring one business day's notice and no prior Commission review. The Commission has effectively no ability to evaluate whether those contracts meet the public interest standard before they go live and retail participants start losing money on them. Self-certification was designed for incremental additions to well-understood contract categories — not for a gambling company launching thousands of novel retail products annually.
The Commission should require mandatory prior approval for all retail-facing event contracts, full stop.
On Costs and Benefits (Questions 6, 14, 22, 38)
The Commission asks repeatedly about cost-benefit considerations.
The costs of shutting Kalshi down: Kalshi's investors lose money. Kalshi's employees find other jobs. People who wanted to gamble on political outcomes use one of the many other legal gambling venues available to them.
The benefits: People like me — young, not wealthy, targeted by sophisticated marketing for a product designed to extract money from us — are protected. State consumer protection laws are no longer nullified by a federal registration. The integrity of political information is no longer compromised by a speculative market that rewards manipulation. The Commission's own enforcement resources are no longer spread across thousands of contracts no surveillance system was built to monitor.
That is not a close call.
Conclusion
I am unemployed. I have time to read federal register notices and submit comments. Most people my age who have been hurt by platforms like Kalshi do not. They are too embarrassed, too overwhelmed, or simply do not know this process exists.
I am asking the Commission to act as though it heard from all of them — because in a sense, it has.
Revoke Kalshi's designation. Ban these contracts. Stop letting a gambling company hide behind a commodity exchange license while it takes money from people who can least afford to lose it.
