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Comment for Proposed Rule 91 FR 12516

  • From: Zach Hillman
    Organization(s):

    Comment No: 115870
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Zach Hillman, and I'm a regular citizen from Florida writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a couple of years now, and I strongly support the idea of well-regulated prediction markets in the United States.


    I got into prediction markets because I wanted better information about elections and public events. Polls and pundits are often wrong or biased, but the prices on these markets cut through the noise. They give me a clearer picture of what's likely to happen, whether it's a presidential race or a major policy decision. This isn't just helpful for me; I think it benefits everyone when we have access to more accurate forecasts. It's not gambling, either. I spend time researching and thinking through probabilities, just like I would for any other investment.


    What really matters to me is having safe, regulated places to trade. Platforms like Kalshi, which operate under CFTC oversight as a designated contract market, give me confidence that my money is protected and the rules are clear. I've also used offshore platforms like Polymarket, and I can tell you they're nowhere near as secure. Theres no real recourse if something goes wrong, and I worry about fraud or manipulation. If the CFTC over-restricts or bans prediction markets here, people like me will just get pushed to those unregulated sites. Thats not safer for anyone.


    I also want to address a concern I know comes up, especially around insider trading or manipulation. I get why that's a worry, but the CFTC already has laws and tools to tackle those issues. Banning or overly limiting these markets punishes regular folks like me who are just trying to make informed decisions. It's not fair to shut down something valuable because of a few bad actors.


    I noticed a few questions in the ANPR that relate to my perspective. On Question 7, about balancing innovation and consumer protection, I think regulated markets strike the right balance by encouraging innovation while keeping users safe. On Question 29, about inside information, I believe the focus should be on enforcing existing laws rather than restricting entire markets. And for Question 15, on defining legitimate markets, Id argue that event contracts for elections and public events serve a real purpose in forecasting and shouldnt be labeled as gaming.


    I urge the CFTC to support proportionate regulation of prediction markets. Dont ban or overly restrict them. Keep platforms like Kalshi operating under clear rules so everyday people like me can participate safely without being forced offshore. Thanks for considering my input.


    Sincerely,

    Zach Hillman

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