Comment Text:
Dear Chairman and Commissioners,
My name is Mykah Cummings, and I'm a trader and investor from Washington state. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets. As someone who actively trades on platforms like Kalshi, I've found tremendous value in these markets, especially in an economy where making a living off a regular job is tougher than ever. They've helped me pull in extra money for my family, and I believe they offer real benefits to society as a whole.
I trade on Kalshi regularly, and it's not gambling in my view. The prices are set by people like me who research and make informed decisions about real-world events. It's no different from using judgment to invest in stocks or commodities. Prediction markets give me unique information I can't get from polls or pundits, often with better accuracy on things like elections or economic indicators. That benefits everyone, not just traders. They also let me hedge personal risks, like betting on policy changes or economic data releases that could impact my finances. For businesses, this hedging utility is even more critical, protecting against regulatory shifts or other uncertainties.
I understand there are concerns about manipulation or insider trading, and those are valid worries. But the CFTC already has powerful tools to tackle these issues, just as they do in other derivatives markets. Banning or over-restricting prediction markets isn't the answer; it just punishes regular folks like me and pushes trading to unregulated offshore platforms where there's no oversight at all. Regulated markets like Kalshi are far safer, with transparency and consumer protections in place. I'd rather see the CFTC focus on targeted rules to address specific risks than broad categorical bans.
On some of the specific questions in the ANPR, I have thoughts on a few. For Question 8 under Public Interest, I believe prediction markets serve the public good by improving price discovery and forecasting accuracy, which helps everyone make better decisions. For Question 15 under Listed Activities, I strongly feel event contracts shouldn't be classified as gaming; they have legitimate economic purposes like hedging and information aggregation. And on Question 29 under Inside Information, I think informed trading actually improves price discovery and benefits all participants, as long as existing laws against insider trading are enforced.
The US should be leading in financial innovation, not falling behind other countries. Prediction markets are here to stay, and I urge the CFTC to support proportionate regulation that keeps them accessible to regular people like me while addressing real risks with the tools you already have. Don't let over-regulation drive this valuable tool offshore. Thank you for considering my input.
Sincerely,
Mykah Cummings
