Comment Text:
Dear Chairman and Commissioners,
My name is CJ Ma, and I'm a software engineer from Kansas. Im 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). As someone who actively trades on platforms like Kalshi, Ive seen firsthand how these markets provide unique value, both to me personally and to society at large. I want to share why I believe the CFTC should support well-regulated prediction markets rather than imposing overly restrictive rules or bans.
As a tech professional, Im drawn to systems that aggregate information efficiently, and prediction markets do exactly that. Ive used Kalshi to trade on events like election outcomes and economic indicators, and the prices often reflect a clearer picture of whats likely to happen than any poll or pundit Ive come across. This isnt just helpful for traders like me; its valuable for anyone making decisions, whether its a business planning for policy changes or a citizen trying to understand the odds of a major event. These markets democratize access to insights that would otherwise be locked away with big institutions.
I also want to stress that event contracts arent gambling. When I trade on Kalshi, Im not rolling dice. Im researching data, analyzing trends, and making informed judgments, much like I would with stocks or other investments. Classifying these as gaming undercuts their real economic purpose, like price discovery and hedging against uncertainty. For example, Ive used these markets to hedge personal financial risks tied to interest rate decisions. Thats not a game; its a practical tool.
Im concerned that banning or over-restricting prediction markets will push activity to unregulated offshore platforms. Id much rather trade on a CFTC-regulated site like Kalshi, where there are consumer protections in place, than take my chances with some shady overseas operation. Regulation keeps us safe; prohibition just drives us underground. Plus, the US has a chance to lead in financial innovation here. If we stifle these markets, other countries will step in and take the lead.
Turning to some of your specific questions, I think Question 7 on balancing innovation and consumer protection is key. Regulation should focus on transparency and preventing manipulation, not broad bans. On Question 15 about defining gaming, I urge you not to lump event contracts into that category; they serve legitimate purposes, as Ive described. And regarding Question 11 on public interest, I believe the forecasting accuracy of these markets, backed by academic research, serves the public good by providing better data for everyone.
I appreciate the CFTCs concern about risks like insider trading or manipulation, but those are already illegal and can be addressed with existing tools. Shutting down prediction markets to stop a few bad actors punishes the rest of us who use them responsibly. I urge you to support proportionate regulation that allows legal, regulated markets to thrive while protecting consumers. Lets keep this innovation alive in the US.
Thank you for considering my input.
Sincerely,
CJ Ma
