Comment Text:
Dear Chairman and Commissioners,
My name is Matheus Rabello, a full-time trader and investor based in California. I've been actively trading on Kalshi 24/7 since February, and in my experience, it's the best prediction market platform out there, hands down. It's fair, transparent, and gives people like me a real chance to engage with markets that matter. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to urge the CFTC to support well-regulated prediction markets with proportionate rules, not bans or over-restrictions.
I believe prediction markets are incredibly valuable, both to me personally and to society. They produce forecasts that are consistently more accurate than polls or pundits, providing information you can't get anywhere else. As a trader, I use platforms like Kalshi to hedge real financial risks tied to events like economic data releases or policy changes that could impact my investments. This isn't gambling; it's a legitimate economic tool that takes research and judgment, just like trading stocks or commodities. Classifying event contracts as "gaming" would be a mistake, as they serve clear purposes like price discovery and risk management.
I'm also concerned about over-regulation pushing activity offshore to unregulated platforms. I've seen how Kalshi operates under CFTC oversight, and that structure keeps things safe and transparent. Banning or heavily restricting these markets would just drive traders like me to less secure venues. The CFTC already has strong tools to tackle manipulation and insider trading in other derivatives markets. Those same tools can work here without resorting to blanket prohibitions. In fact, informed trading improves price discovery and benefits everyone in the market, not just the traders.
On a specific note, I want to address something that affects my day-to-day trading: artificial delays in processing live-event orders. I strongly believe these delays, whether for makers or takers, should be prohibited on all regulated prediction market platforms. Kalshi operates with zero artificial seconds, and that's how it should be everywhere. Delays create unfair advantages for whoever sees new information first, forcing the rest of us to trade on stale prices. Removing these lags leads to better price discovery by reflecting reality in real time, levels the playing field for retail and professional traders, and makes hedging more effective for real-world risks. It also boosts liquidity, reduces distortion risks, and doesn't even stop issues like courtsiding, since those exploiting delays can just time their trades to the predictable lag. If prediction markets are about aggregating information fast, artificial delays run counter to their very purpose. I urge the CFTC to consider this under questions related to core principles and regulations, like Question 1 on manipulation prevention, and public interest considerations in Questions 7-14.
Prediction markets are the future, and I truly believe professional trading in this space will become a major career path. The U.S. should lead in this innovation with smart, balanced rules. Please support proportionate regulation that protects participants without stifling these valuable markets.
Sincerely,
Matheus Rabello
