Comment Text:
Dear Chairman and Commissioners,
My name is Lucas Lima, and I'm a trader and investor based in Florida. I'm writing to express my strong support for the proportionate regulation of prediction markets as outlined in the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I've seen firsthand how valuable these markets are, both for me personally and for society at large.
As a trader, I rely on prediction markets for information that I simply can't get anywhere else. Their forecasts on elections and other public events have consistently been more accurate than polls or pundits. That kind of insight helps me make better decisions, not just in trading but in understanding the world around me. I also use these markets to hedge real financial risks. For instance, I've traded contracts tied to economic indicators that affect my investments, like interest rate decisions. This isn't gambling, it's a practical tool, much like trading stocks or commodities, requiring research and judgment about real-world events.
I know there are concerns about manipulation or insider trading, and I get why those are issues. But the CFTC already has strong tools to tackle these problems. Fraud and manipulation are illegal, and your existing authority covers these markets just as it does others. Banning or over-restricting prediction markets because of a few bad actors feels like punishing everyone for something most of us aren't doing. Instead, targeted rules to address specific risks make more sense. Plus, informed trading actually improves price discovery, which benefits everyone, not just traders like me.
I'm also worried about what happens if the U.S. over-regulates or pushes these markets away. Regulated platforms like Kalshi are safe and transparent, but if access is restricted, people will just turn to offshore alternatives with no oversight. Thats worse for consumer protection. The U.S. has a chance to lead in financial innovation here, and I believe we should seize it, not cede ground to other countries.
I'd like to address a couple of specific questions from the ANPR. On Question 7, regarding public interest, I believe prediction markets serve the public by providing better information for decision-making, whether it's for individuals, businesses, or even policymakers. On Question 29, about inside information, I think informed traders help make prices more accurate, and existing laws already bar federal officials or others from abusing nonpublic info.
In closing, I urge the CFTC to support well-regulated prediction markets with rules that target real risks without broad bans. These markets are too useful to individuals like me, to businesses hedging risks, and to society seeking better forecasts. Let's keep them accessible and safe under your oversight.
Sincerely,
Lucas Lima
