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Comment for Proposed Rule 91 FR 12516

  • From: Wenrui Jiang
    Organization(s):

    Comment No: 116337
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Wenrui Jiang, and I'm a student based in Colorado with a strong interest in economics and public policy. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my support for well-regulated prediction markets. As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide valuable information and tools that benefit individuals and society.


    I rely on prediction markets for accurate forecasts on elections and other public events. In my studies, I've noticed that these markets consistently outperform polls and pundits in predicting outcomes. That kind of data isn't just useful for traders like me; it helps everyone, from journalists to policymakers, make better decisions. Beyond forecasting, I also use these markets to hedge personal financial risks. For example, trading on contracts tied to economic indicators helps me think through how policy changes might impact my future as a student entering a volatile job market.


    I want to be clear that I don't see this as gambling. Trading on prediction markets requires research and real-world judgment, much like investing in stocks. Classifying event contracts as "gaming" (as discussed in Questions 15-22) ignores their legitimate economic purpose, like price discovery and risk management. I'm also worried about the idea of over-restricting or banning these markets. If the U.S. pushes activity offshore to unregulated platforms, as opposed to safe, CFTC-registered markets like Kalshi, consumers like me lose protection. Id rather see the U.S. lead in financial innovation than cede that space to other countries.


    On the topic of manipulation and insider trading (Questions 29-32), I believe the CFTC already has strong tools to address bad actors. Banning entire markets to stop a few cheaters punishes everyone else and doesnt solve the problem. In fact, informed trading often improves price accuracy, benefiting all participants. My academic background also makes me value the transparency and data these markets generate. Research shows they aggregate information efficiently, and I hope the CFTC considers this public benefit (Questions 7-14) when crafting rules.


    I urge you to adopt proportionate, targeted regulations rather than broad restrictions. Focus on specific risks with existing tools instead of categorical bans. This approach will protect consumers, support innovation, and keep the U.S. competitive. Thank you for considering my perspective as a student and active market participant.


    Sincerely,

    Wenrui Jiang

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