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Comment for Proposed Rule 91 FR 12516

  • From: Sulaiman Sherzad
    Organization(s):

    Comment No: 116048
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Sulaiman Sherzad, and I'm a civil engineer based in Wisconsin. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets. Ive been trading on platforms like Kalshi for a while now, and Ive seen firsthand how these markets provide real value, both to me personally and to society at large.


    As an engineer, my work often depends on understanding economic and political events that can impact construction projects, like changes in interest rates or new infrastructure policies. Prediction markets give me a way to hedge against some of these uncertainties. For instance, Ive used event contracts to offset risks tied to potential delays or cost increases from regulatory shifts. This isnt gambling, not by a long shot. Its a practical tool for managing real-world risks, much like any other financial instrument. I believe these markets serve a legitimate economic purpose, and labeling them as "gaming" misunderstands their function.


    I also want to stress that regulated platforms like Kalshi are far safer than the alternative. If the CFTC over-restricts or bans these markets, people like me wont just stop trading. Well be pushed to unregulated offshore platforms with no oversight, no consumer protections, and no accountability. Thats a much bigger risk to everyone involved. Keeping prediction markets under CFTC supervision ensures transparency and helps prevent fraud or manipulation.


    On that note, Im concerned about broad categorical bans or overly harsh rules. I understand the need to address issues like insider trading or market manipulation, and Im not dismissing those risks. But the CFTC already has tools to tackle bad actors without punishing the rest of us. Targeted, proportionate regulation makes more sense than sweeping restrictions. Id urge you to consider specific safeguards instead of outright prohibitions, especially in response to questions 7 through 14 on balancing innovation with consumer protection, and questions 23 through 28 on how public interest determinations are made.


    Prediction markets arent just a niche hobby. Theyre a valuable way for individuals and businesses to manage uncertainty and make informed decisions. Im asking the CFTC to support a regulatory framework that allows these markets to thrive while addressing legitimate concerns with focused, practical rules. Dont let overregulation drive this innovation underground or overseas.


    Thank you for considering my input.


    Sincerely,

    Sulaiman Sherzad

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