Comment Text:
Dear Chairman and Commissioners,
My name is Christian Jalim, and I'm a student from Pennsylvania 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 I strongly support the development of well-regulated prediction markets in the United States. I believe they offer unique value to individuals like me, to businesses, and to society as a whole, and I urge the CFTC to adopt proportionate regulations rather than overly restrictive rules or bans.
As a student, Ive seen firsthand how prediction markets provide information thats often more accurate than polls or pundits. Whether its forecasting election outcomes or economic indicators, these markets cut through the noise and give a clearer picture of whats likely to happen. This isnt just helpful for traders; its valuable for anyone making decisions, from policymakers to everyday citizens. I also think theres a real academic benefit here. The data from these markets could be a goldmine for research, helping us better understand public sentiment and economic trends if made transparent under proper regulation.
I trade on Kalshi because its a regulated platform, which feels much safer than the offshore alternatives out there. If the CFTC over-restricts or bans these markets, I worry activity will just move to unregulated spaces where theres no consumer protection at all. Thats a worse outcome for everyone. The US has a chance to lead in financial innovation by setting a global standard for how prediction markets should work. We shouldnt cede that opportunity to other countries.
I also want to stress that event contracts arent gambling. They serve real economic purposes, like price discovery and hedging risks. For example, Ive used markets to hedge personal financial uncertainties tied to policy changes or economic data releases. Businesses can do the same for regulatory or political risks. Classifying these as gaming feels like a misunderstanding of their value. On the topic of informed trading, I believe it actually improves price discovery, as noted in questions 29-31 of the ANPR. Banning markets over fears of insider trading ignores that such behavior is already illegal and that the CFTC has tools to address it without punishing everyone else.
Im not blind to the risks. Manipulation or fraud is a concern, but broad categorical bans arent the answer. Targeted rules, as discussed in questions 1-6 on core principles, can address specific issues like manipulation while allowing legitimate markets to thrive. Proportionate regulation is the way to balance innovation with protection, as explored in questions 7-14 on public interest.
I ask the CFTC to support regulated prediction markets with fair, targeted rules. Dont let over-restriction push this valuable tool offshore or out of reach for regular people like me. Thank you for considering my perspective.
Sincerely,
Christian Jalim
