Comment Text:
Dear Chairman and Commissioners,
My name is Myktybek Imankulov, and I'm a trader and investor based in North Carolina. I've been actively trading on prediction markets like Kalshi for a while now, and I wanted to share my perspective on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets, and I hope my input helps shape a balanced approach to this growing space.
As someone who trades regularly on platforms like Kalshi, I can tell you firsthand that event contracts are not gambling. They serve real economic purposes. I put time and effort into researching economic data, political events, and policy trends before making trades. It's no different from the analysis I do for stocks or commodities. These markets let me hedge against uncertainties, like how a Federal Reserve decision might impact my financial planning or how an election outcome could affect my investments. Labeling this as "gaming," as discussed in Questions 15-22, ignores the legitimate value these contracts provide for price discovery and risk management.
I also believe that informed trading makes these markets better for everyone. When people like me bring knowledge to the table, it improves the accuracy of the prices, which benefits not just traders but anyone looking for reliable signals about future events. Academic research backs this up, showing how prediction markets often outperform polls and pundits. This ties directly to Questions 29-32 on inside information and price discovery. Yes, insider trading is a concern, but it's already illegal, and the CFTC has tools to address it without shutting down entire markets. Banning or over-restricting prediction markets punishes honest participants and pushes activity to less safe, unregulated offshore platforms.
That's a big worry for me. Regulated markets like Kalshi, operating under CFTC oversight, provide transparency and accountability that you won't find on offshore sites. If the U.S. cracks down too hard, traders will just go elsewhere, and that helps no one. I'd much rather see the CFTC focus on proportionate rules that keep markets fair and open, as raised in Questions 7-14 on balancing innovation and consumer protection. Freedom to participate in legal, regulated markets is important to me as an individual investor. I don't want to see access limited to big institutions while regular folks like me are locked out.
In closing, I urge the CFTC to support prediction markets with sensible regulations that address specific risks without broad bans or overly harsh restrictions. These markets provide unique value through better forecasting and hedging opportunities, and they deserve a fair framework to thrive under your oversight.
Sincerely,
Myktybek Imankulov
