Comment Text:
Dear Chairman and Commissioners,
My name is Kokou Saka, and I'm a student based in Washington state. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I strongly support the development of well-regulated prediction markets, and I hope the CFTC will craft rules that encourage innovation while addressing real risks.
Prediction markets have been incredibly valuable to me, both as a student studying public events and as an individual trying to make sense of an uncertain world. I've used platforms like Kalshi to trade on election outcomes and economic indicators, and the prices often give me insights I can't find in polls or news. I believe this kind of forecasting is a public good. It helps not just traders like me, but also journalists, policymakers, and anyone who needs better data to make decisions. Academic research backs this up, showing prediction markets consistently outperform traditional forecasts.
I also see these markets as a way to hedge personal risks. For example, trading on economic events like inflation reports helps me think through how changes might affect my budget or future plans as a student. This isn't gambling. It takes research and judgment, much like investing in stocks. I worry that labeling event contracts as "gaming," as discussed in Questions 15-22 of the ANPR, ignores their real economic purpose. They aren't just games of chance; they help people like me manage uncertainty.
I'm all for consumer protection, but I think the CFTC already has strong tools to handle issues like manipulation and insider trading, as touched on in Questions 1-6 and 29-32. Banning or over-restricting prediction markets, instead of using those tools, would push activity to unregulated offshore platforms where there's no oversight. I've seen friends use offshore sites, and theyre far riskier than regulated markets like Kalshi. The US should lead in financial innovation, not cede ground to other countries. Proportionate, targeted rules are the way to go, not broad categorical bans.
One last thought, on a personal note. Im a big soccer fan, and while trading on sports outcomes isn't always allowed, I think adding more detailed markets, like predicting specific players performance, could make these platforms even more engaging and useful for analysis, if done responsibly.
I urge the CFTC to support prediction markets with fair, balanced regulation that protects consumers without stifling innovation. Let's keep these markets accessible to everyday people like me, and ensure the US remains a leader in this space. Thank you for considering my input.
Sincerely,
Kokou Saka
