Comment Text:
Dear Chairman and Commissioners,
My name is Herdian Kusuma, and Im a software engineer based in New York. Im writing to provide my input 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 and Polymarket, I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to individuals like me, as well as to businesses and society at large.
I got into prediction markets a couple of years ago because I wanted better insights into elections and major public events. As a tech professional, Im used to digging through data to solve problems, and I found that the prices on these markets often cut through the noise of pundits and polls. Theyve helped me make sense of complex events and even hedge personal financial risks tied to policy changes, like tax reforms that could impact my freelance income. I know businesses use these markets too, to hedge against regulatory or economic shifts. This isnt gambling to me; its a practical tool that takes research and judgment, just like any other investment.
Im also a big believer in the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, give people like me a safe way to engage. If you over-restrict or ban these markets, activity will just move to unregulated offshore platforms where theres no consumer protection at all. Ive seen some of those sites, and theyre a mess, with no accountability. Regulation, not prohibition, is the way to keep users safe.
I want to address a concern I know the CFTC has about manipulation and insider trading, especially in relation to questions 29-32 in the ANPR. I understand the worry, but I believe the CFTC already has strong tools to tackle these issues. Insider trading and market manipulation are illegal, and your existing authority over derivatives markets can be applied here. Punishing everyone by shutting down prediction markets because of a few bad actors doesnt make sense to me. Its like closing the stock market over a few insider trades. Instead, focus on enforcing the rules you already have.
I also want to touch on questions 7-14 about public interest and consumer protection. Prediction markets balance innovation with real utility, like accurate forecasting and risk hedging. Protecting consumers means ensuring regulated options exist, not driving us to sketchy alternatives.
I urge the CFTC to support proportionate regulation of prediction markets. Dont ban or overly restrict them. Keep platforms like Kalshi accessible under clear, fair rules that protect users and maintain market integrity. Thank you for considering my perspective.
Sincerely,
Herdian Kusuma
