Comment Text:
Dear Chairman and Commissioners,
My name is Samuel Litzen, and I'm a trader and investor based in Montana. I've been actively trading on prediction markets like Kalshi for a while now, and I want 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 I hope my perspective as someone who uses these platforms can help inform your approach.
Trading on prediction markets isn't just a hobby for me; it's been a lifeline. I struggle with depression, and having a way to engage with the world through these markets, analyzing events, and making informed trades gives me a sense of purpose and focus. It's not about gambling, it's about research and judgment. I put in the time to understand economic indicators, political events, and other real-world factors, just like I do when I invest in stocks or other assets. Calling event contracts "gaming" feels wrong when they serve a clear economic purpose, like price discovery and hedging against uncertainty. I often trade on outcomes that could affect my investments, like interest rate decisions or election results, and that helps me manage risk in a way I can't do elsewhere.
I'm also worried about what happens if these markets get banned or over-restricted. Right now, platforms like Kalshi are regulated by the CFTC, which means there are rules, oversight, and protections in place. If you make it too hard for legitimate markets to operate, people like me will get pushed to unregulated offshore platforms where there's no accountability. I've seen those sites out there, and theyre sketchy at best. No ones watching out for manipulation or fraud on those platforms. Keeping regulated markets like Kalshi accessible is far safer for traders and better for the integrity of the system overall.
I noticed some of the questions in the ANPR, like Question 7 on balancing innovation with consumer protection and Question 15 on defining gaming versus legitimate markets. I think the answer lies in recognizing that event contracts aren't gambling when theyre tied to real economic value. And on the innovation side, regulation should focus on protecting users without killing off a useful tool. Shutting things down or over-restricting them just drives activity into the shadows.
I urge you to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Keep platforms like Kalshi operating under clear, fair rules so people like me can continue to use them safely and responsibly. Thank you for considering my input.
Sincerely,
Samuel Litzen
