Comment Text:
Dear Chairman and Commissioners,
My name is Simran Rahman, and I'm a business owner from Texas. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've actively traded on platforms like Kalshi, and I've seen firsthand how these markets provide value that you just can't get from traditional sources like polls or news media.
During the 2024 U.S. election, I was in the top 1% of traders on a prediction market, Manifold, for election-related contracts. I watched these markets reflect real-time sentiment far more accurately than any pollster or pundit. For me, this isn't just about making a profit; it's about accessing better information. As a business owner, I rely on accurate forecasts for public events to make decisions about my company. Prediction markets also let me hedge real financial risks, like potential policy changes that could impact my taxes or operations. This isn't gambling. It takes research and judgment, just like trading stocks or commodities. Classifying event contracts as "gaming" ignores their legitimate economic purpose.
Im worried that banning or over-restricting these markets will push activity to unregulated offshore platforms where theres no oversight. The U.S. should be leading in financial innovation, not handing the advantage to other countries. Regulated markets like Kalshi are transparent and safe, and they give regular people like me a chance to participate in a free and fair information market. Broad restrictions feel suppressive, not protective. Academic research backs this up, showing how prediction markets aggregate information efficiently, benefiting everyone, not just traders.
Id like to address a few specific questions from the ANPR. On Question 7, regarding public interest, I believe prediction markets serve the public by improving price discovery and decision-making. On Question 15, about defining gaming, I urge the CFTC to recognize that event contracts aren't gambling but tools for hedging and forecasting. And on Question 23, about procedural aspects, I think public interest determinations should focus on proportionate rules, not categorical bans that punish legitimate users.
I understand concerns about manipulation or insider trading, but the CFTC already has tools to tackle those issues. Punishing everyone by shutting down markets isn't the answer. Instead, I ask that you support targeted regulations that address specific risks while allowing prediction markets to thrive. Let's keep the U.S. at the forefront of financial innovation and ensure regular folks like me can keep using these tools responsibly.
Thank you for considering my input.
Sincerely,
Simran Rahman
