Comment Text:
Dear Chairman and Commissioners,
My name is Stephan Durandisse, and I'm a student from New York. I'm 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 platforms like Kalshi, and I strongly support the development of well-regulated prediction markets in the United States. I believe they offer unique value to society and to individuals like me, and I hope the CFTC will craft rules that encourage innovation while addressing real risks.
As a student, I've found prediction markets to be an incredible tool for understanding the world. The forecasts they produce are often more accurate than polls or pundits, giving me insights into elections, economic trends, and other events that I can't find anywhere else. This isn't just gambling, no matter what some might say. Trading on these platforms takes research and critical thinking, much like investing in stocks. Event contracts serve a real economic purpose, whether it's price discovery or helping people hedge against uncertainty in their lives.
I also believe regulated markets are the way to go. Platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, it won't stop people from trading. It will just push activity to less safe, less transparent venues outside the US. That hurts consumer protection, not helps it. Speaking to Question 7 from the ANPR, on balancing innovation and protection, I think the answer lies in targeted rules, not broad prohibitions. Address specific issues like manipulation or insider trading with focused measures, as you already do in other markets.
On the topic of innovation, raised in Question 11, I worry that overly strict rules could cause the US to fall behind. We should be leading in financial innovation, not ceding ground to other countries. Prediction markets are a chance to show that leadership. And to Question 29 about inside information, I believe informed trading actually improves price discovery. It makes the market's predictions sharper, which benefits everyone, not just traders.
I understand there are concerns about manipulation or unfair advantages. But the CFTC already has tools to tackle those problems. Use them, rather than punishing everyone by limiting access to these markets. I value the freedom to participate in legal, regulated platforms as an individual, not just leaving it to big institutions. Please craft rules that protect consumers without stifling this unique space.
Thank you for considering my perspective. I urge the CFTC to support proportionate regulation of prediction markets and avoid broad bans or excessive restrictions.
Sincerely,
Stephan Durandisse
