Comment Text:
Dear Chairman and Commissioners,
My name is Ethan Stern, and I'm a student from Minnesota. I'm 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 for a while now, and I believe that well-regulated prediction markets are valuable and should be supported, not overly restricted or banned.
As a student, I find prediction markets fascinating because they offer insights you can't get from news or polls. I've used Kalshi to trade on events like election outcomes and economic data releases, and it's helped me understand how people weigh information in real time. It's not just a game to me; it feels like a way to engage with the world, putting my research and judgment to the test. I don't see this as gambling at all. It takes thought and analysis, much like investing in stocks or other financial instruments. To me, event contracts serve a real purpose, whether it's gaining information or even hedging personal risks, like how an election might impact policies that affect my future career or student loans.
What concerns me is the idea of pushing these markets underground. I choose to trade on regulated platforms like Kalshi because I trust that there's oversight to prevent manipulation and ensure fairness. If the CFTC over-restricts or bans these markets, I worry that people like me will turn to unregulated offshore platforms instead. Those places have no accountability, no consumer protections, and no way to ensure fair play. I'd much rather see the CFTC focus on regulating these markets properly, keeping them safe and accessible for regular people like me who want to participate legally. This ties directly to some of the questions in the ANPR, like Question 7 on balancing innovation with consumer protection and Question 23 on how to approach public interest determinations. I think the public interest lies in keeping these markets regulated and open, not shutting them down.
I understand there are concerns about things like insider trading or manipulation, but I believe the CFTC already has tools to address those issues. Punishing everyone by restricting access doesn't seem fair when the problem can be tackled with targeted rules. I want the freedom to participate in legal, regulated markets without fear of them disappearing because of overreach.
In closing, I urge the CFTC to support proportionate regulation of prediction markets. Keep platforms like Kalshi accessible to everyday traders like me, and focus on strong oversight rather than broad restrictions. Thank you for considering my perspective.
Sincerely,
Ethan Stern