Comment Text:
Dear Chairman and Commissioners,
My name is Milan Vos Alfaro, and I'm a student from California, juggling school half-time, two jobs, and the early stages of starting a small business. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support well-regulated prediction markets. I believe they offer real value to people like me and to society as a whole, and I urge you to avoid over-restricting or banning them.
As someone trying to build a small business while managing tight finances, prediction markets are a tool I rely on to hedge risks that hit close to home. For instance, I've used event contracts to offset uncertainties around economic policies that could affect my startup costs or personal budget. This isn't gambling, it's a practical way to protect myself. These markets require research and judgment, much like any other investment. Classifying them as "gaming" undercuts their legitimate economic purpose, and I hope the CFTC recognizes this when addressing questions like 15 to 22 on listed activities.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, under CFTC oversight, give regular folks like me access to tools that would otherwise be locked away for big institutions. Banning or over-restricting these markets won't stop trading, it'll just push it offshore to unregulated spaces where there's no accountability. That's a worse outcome for everyone. On this point, I think your questions 7 to 14 on public interest really hit the nail on the head, and I hope you prioritize keeping these markets accessible and safe within the US.
On top of that, the US should be a leader in financial innovation. We shouldn't cede this space to other countries by piling on unnecessary rules. Prediction markets are a cutting-edge way to aggregate information and forecast outcomes, often more accurately than polls or pundits. Letting them thrive here keeps us competitive. And honestly, the less government meddling, the better. Don't ruin something useful and fun by over-regulating it. That's not the American way.
I'm not blind to the concerns about manipulation or insider trading, but the CFTC already has tools to tackle those issues, as noted in questions 29 to 32 on inside information. Use those existing powers instead of broad restrictions that punish everyone for the actions of a few.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Keep them legal, accessible, and under sensible oversight, but don't ban or choke them with red tape. They're too valuable for people like me trying to navigate an uncertain world.
Sincerely,
Milan Vos Alfaro
