Comment Text:
Dear Chairman and Commissioners,
My name is Damian Mesa, and I'm a student from Nevada writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on regulated prediction markets like Kalshi, and I believe these platforms offer real value to people like me and to society as a whole. I want to urge the CFTC to support proportionate regulation of these markets rather than imposing bans or overly restrictive rules.
As a student, I find prediction markets incredibly useful for understanding the world around me. The prices on platforms like Kalshi often provide better insights into elections and public events than polls or pundits. I've used these markets to follow political outcomes that affect my future, like policies on student loans or taxes. It's not just about trading; it's about getting access to information that helps me make sense of complex issues. This forecasting value, as I see it, benefits everyone, not just those of us who participate.
I also believe event contracts aren't gambling. They serve real economic purposes, like hedging risks or discovering prices based on collective knowledge. I've put time into researching before I trade, just like someone investing in stocks would. Labeling this as gaming feels unfair and ignores the legitimate skills and judgment involved. Plus, informed trading by people who know the issues can actually make prices more accurate, which helps everyone. I think the CFTC should consider this when addressing questions like 7 and 8 on balancing innovation with consumer protection, and question 15 on defining gaming versus legitimate markets.
Another big concern for me is U.S. competitiveness. If the CFTC over-restricts prediction markets, it risks pushing activity to unregulated offshore platforms where there are no safeguards. I've traded on Kalshi because it's regulated and transparent, but if that option goes away, people will just go elsewhere, to less safe venues. The U.S. should be leading in financial innovation, not handing that advantage to other countries. This ties directly to questions 13 and 14 about the public interest and comparing prediction markets to other tools.
I get that there are worries about manipulation or insider trading. But banning or heavily restricting these markets isn't the answer. Punishing everyone for the actions of a few bad actors doesn't make sense. The CFTC already has tools to tackle fraud and manipulation, and those should be applied here too. I'd ask you to look at questions 29 through 32 on insider information and focus on targeted rules, not broad prohibitions.
Finally, I'm just a regular person who values the freedom to participate in legal, regulated markets. Prediction markets give people like me a stake in understanding the world. I hope the CFTC will regulate these platforms in a way that keeps them accessible and safe without stifling their potential.
Thank you for considering my input.
Sincerely,
Damian Mesa