Comment Text:
Dear Chairman and Commissioners,
My name is Eric Myles, and I'm a student based in California. I've been following the CFTC's Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) with great interest, and I want to share my perspective as someone who actively trades on platforms like Kalshi and Polymarket. I strongly support the idea of well-regulated prediction markets and believe they serve important economic purposes for individuals like me, as well as for businesses and society at large.
As a student, I don't have a huge income, but I find prediction markets incredibly useful for both learning and managing small risks. I've used platforms like Kalshi to hedge against outcomes that could impact my finances, like betting on inflation numbers that affect my student loan decisions or rent costs. This isn't gambling to me. It takes research and real-world judgment, much like investing in stocks. Classifying event contracts as "gaming," as discussed in Questions 15-22, ignores the legitimate hedging and price discovery roles these markets play. I believe they should be treated as economic tools, not games of chance.
I'm also concerned that banning or over-restricting these markets, as hinted at in some of the CFTC's past actions, would push activity to unregulated offshore platforms. I've seen how platforms like Polymarket operate with less oversight, and it feels far riskier compared to a regulated market like Kalshi. Addressing Questions 7-14 on public interest, I think regulated markets strike a balance between innovation and consumer protection. They keep activity safe and transparent, while still letting regular people like me participate. If you clamp down too hard, you'll just drive users to less safe spaces.
On the issue of manipulation and insider trading raised in Questions 29-32, I get the concern. Bad actors are a problem in any market. But the CFTC already has strong tools to tackle fraud and manipulation in other derivatives markets. Those can be adapted here without resorting to broad bans. Plus, informed trading often improves price discovery, making predictions more accurate for everyone, not just traders. Shutting down markets to stop a few bad actors feels like punishing the majority for the actions of a few.
I urge the CFTC to support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules. Don't over-restrict or ban broad categories of event contracts. Keep platforms accessible to everyday people like me, and ensure the US leads in financial innovation rather than ceding ground to offshore markets. Thank you for considering my input.
Sincerely,
Eric Myles
