Comment Text:
Dear Chairman and Commissioners,
My name is Deborah Ekenavie, and I'm a small business owner from Rhode Island and I've been actively trading on prediction markets like Kalshi for the past year. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support well-regulated prediction markets and believe they provide real value to people like me, as well as to society at large.
As a business owner, I deal with a lot of uncertainty, whether it's changes in consumer spending, new regulations, or economic shifts tied to political events. Trading on prediction markets has given me a way to hedge some of that risk. For example, I've placed trades on election outcomes that could impact small business taxes or local policies here in Rhode Island. This isn't just a game to me; it's a practical tool. I put in time to research and think through my decisions, just like I do when making business investments. That's why I find it frustrating when event contracts are labeled as "gaming." They serve a legitimate economic purpose, like price discovery and risk management, and shouldn't be treated like gambling. I urge you to consider this distinction when addressing Questions 15-22 about listed activities and how to define these markets.
I also value my freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, give me confidence that there's transparency and accountability. But if prediction markets are banned or over-restricted, I worry that activity will just move to offshore platforms with no oversight. Thats not safer for anyone. It would cut people like me out of a useful tool and push trading to places where there are no rules at all. I think your focus should be on smart regulation, not prohibition, and I hope you'll explore this in Questions 7-14 on balancing innovation and consumer protection.
I understand there are concerns about manipulation or insider trading. Those are real issues, but the CFTC already has tools to address them. Banning entire markets to stop a few bad actors feels like overkill and punishes the rest of us who use these platforms responsibly. Let's focus on enforcing existing laws instead of shutting down something valuable.
I'm asking you to support proportionate regulation of prediction markets. Keep them legal and accessible on regulated platforms, and don't let overly restrictive rules drive this activity offshore or underground. Thank you for considering my perspective as a small business owner who relies on these tools.
Sincerely,
Deborah Ekenavie
