Comment Text:
Dear Chairman and Commissioners,
My name is Guillermo Escudero, and I'm just an everyday citizen from Arizona writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been following this issue because I actively trade on prediction markets like Kalshi and Polymarket, and I believe these platforms have real value when they're regulated properly.
I started trading on these markets for fun, placing small bets on things like election outcomes or economic data releases. But over time, I realized theyre more than just a hobby. Theyve helped me hedge some personal financial risks. For example, Ive used prediction markets to offset potential losses tied to policy changes that could impact my taxes or costs as a regular person trying to make ends meet. Its not gambling to me; its a practical tool. I do my research, follow the news, and make informed decisions, just like I would with any other investment.
What worries me is the idea of over-restricting or banning these markets. Ive traded on both regulated platforms like Kalshi, which operates under CFTC oversight, and unregulated offshore ones like Polymarket. The difference is night and day. On a regulated market, I feel safer knowing there are rules in place, transparency, and a way to resolve disputes. Offshore platforms? Its a gamble in itself. No oversight, no accountability. If something goes wrong, good luck getting help. Banning or overly restricting prediction markets in the US would just push people like me to those less safe, unregulated sites. Thats not protecting anyone; its making things worse.
Im glad the CFTC is asking for input, and I want to address a couple of your specific questions. On Question 7, about balancing innovation and consumer protection, I think regulated prediction markets strike that balance. They let regular folks like me participate and gain valuable insights while having safeguards in place. And on Question 29, regarding inside information, I believe the CFTC already has tools to tackle manipulation or insider trading. Dont punish the whole market for a few bad actors; enforce the rules youve got.
Prediction markets give me access to information and financial tools I cant get anywhere else. Theyre often more accurate than polls or pundits, and they let everyday people have a stake in understanding whats happening in the world. Im asking you to support proportionate regulation of these markets. Dont ban them or make the rules so tight that only big institutions can play. Keep platforms like Kalshi accessible and safe for people like me, and dont drive us to risky offshore alternatives.
Thank you for considering my perspective.
Sincerely,
Guillermo Escudero
