Comment Text:
Dear Chairman and Commissioners,
My name is Eugene Mbogo, and I'm a trader and investor from Pennsylvania, currently studying Finance and AI at the Wharton School of Business. I'm writing to express my strong support for the proportionate regulation of prediction markets as outlined in the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide unique value, and I believe the CFTC has an opportunity to foster innovation while protecting consumers.
Prediction markets are not just a niche interest for me; theyre a tool that delivers better information than polls or pundits ever could. Ive relied on platforms like Kalshi to gauge election outcomes and other public events, and their forecasts have consistently outperformed traditional sources. This isnt gambling. Its about research, analysis, and judgment, much like trading stocks or commodities. Classifying event contracts as "gaming" ignores their real economic purpose, like price discovery and risk management. For instance, Ive used these markets to hedge personal financial risks tied to policy changes that could impact my investments or future business plans. This kind of hedging isnt a game; its a practical way to manage uncertainty.
I also worry that over-restricting or banning these markets will push activity to unregulated offshore platforms. Id much rather trade on a CFTC-regulated market like Kalshi, where there are clear rules and oversight, than take my chances with less safe alternatives. The US should be leading in financial innovation, not ceding ground to other countries. Regulated markets ensure consumer protection and keep activity transparent. Plus, the CFTC already has strong tools to tackle manipulation and insider trading in other derivatives. Those same tools can work here without resorting to broad bans. Targeted regulation, not categorical prohibitions, is the way forward.
Id like to address a few specific questions from the ANPR. On Question 7 under Public Interest, I believe prediction markets serve the public good by improving forecasting and decision-making for everyone, not just traders. On Question 15 under Listed Activities, event contracts should be recognized for their legitimate purposes, not lumped in with gaming. And on Question 29 under Inside Information, I think informed trading actually helps price discovery, making markets more accurate for all participants, as long as existing insider trading laws are enforced.
Prediction markets are a powerful tool for forecasting, hedging, and democratizing information. I urge the CFTC to support their growth through balanced regulation that addresses specific risks without stifling innovation. Lets keep the US at the forefront of financial markets while ensuring safety and transparency.
Thank you for considering my input.
Sincerely,
Eugene Mbogo
