Comment Text:
Dear Chairman and Commissioners,
My name is Russell Lucas, and I'm a welder from Oklahoma. I've been trading on prediction markets like Kalshi for a while now, and I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). Im not a Wall Street guy or some big investor, just a regular person using these markets to manage financial risks that affect my life.
As a welder, my income can swing based on economic shifts or policy changes. I use prediction markets, especially short-term crypto event contracts, to offset some of that uncertainty. This isn't a game to me. It's a practical way to protect myself against volatility, kind of like how Id buy insurance for my truck. These markets give me information I can't find anywhere else, and the prices often seem more reliable than what I hear from news or polls. I think that's valuable not just for me, but for anyone trying to make sense of the world.
Im worried that if the CFTC cracks down too hard, folks like me will lose access to a useful tool. Worse, I know the demand for these markets wont just vanish. If platforms like Kalshi get shut out, people will turn to offshore sites with no rules or protections. Thats a bigger risk to everyone. I hope, when looking at Questions 7 to 14 on public interest, you consider how pushing activity to unregulated spaces could backfire.
I also dont think these contracts should be labeled as gaming, like some of Questions 15 to 22 suggest. Trading on Kalshi takes research and judgment, same as picking stocks or betting on commodity prices. Its not a slot machine. Its a legitimate way to manage risk. And on the topic of insider trading from Questions 29 to 32, I get the concern. But isnt that already illegal? The CFTC has tools to catch bad actors without banning entire markets. Punishing everyone for a few cheaters doesnt seem right to me.
I believe the U.S. should be a leader in financial tools like this, not leave it to other countries. Regulated markets are safer than the wild west of offshore platforms. So, Im asking you to support fair rules that let regular people like me keep participating, while still keeping things in check. Dont over-restrict or ban these markets. Focus on targeted oversight instead.
Thanks for taking the time to read this.
Sincerely,
Russell Lucas
