Comment Text:
Dear Chairman and Commissioners,
My name is Amrit Saab, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing to express my strong support for well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to people like me and to society as a whole, and I hope the CFTC will regulate them in a way that allows them to thrive.
As someone who trades regularly, Ive seen firsthand how prediction markets offer insights you just cant get from polls or pundits. Ive watched these markets predict election outcomes and economic events with far more accuracy than most talking heads on TV or even well-funded surveys. For example, last year on Kalshi, I traded contracts tied to election results, and the market prices consistently reflected a clearer picture of what was likely to happen compared to the endless back-and-forth in the media. This isnt just useful for traders like me, its valuable for anyone trying to make sense of an uncertain world, from journalists to policymakers.
I also want to push back on the idea that event contracts are gambling. Theyre not. Trading on these markets takes research, analysis, and real-world judgment, much like trading stocks or commodities. Im not rolling dice, Im making informed decisions based on data and trends. These markets serve legitimate economic purposes, like price discovery and even hedging against uncertainty. If Im worried about a policy change impacting my investments, a prediction market can help me offset that risk. Calling this gaming feels like a misunderstanding of whats really happening here.
I know there are concerns about things like insider trading or manipulation, and I get that. Those are real issues. But the answer isnt to ban or over-restrict these markets. Insider trading is already illegal, and the CFTC has tools to tackle manipulation in other derivatives markets. Use those same tools here. Shutting down prediction markets to stop a few bad actors would punish regular traders like me who are just trying to make informed decisions.
Id like to specifically address a couple of questions from your ANPR. On Question 8 under Public Interest, I believe prediction markets absolutely serve the public by providing better forecasts than traditional methods, and that benefit outweighs the risks if regulation is done right. And on Question 15 under Listed Activities, I urge you not to classify event contracts as gaming. Theyre a financial tool, not a game of chance.
I hope the CFTC will support proportionate regulation that lets prediction markets continue to grow while addressing specific risks with targeted rules. Dont let overblown fears lead to bans or restrictions that hurt regular traders and the broader public who benefit from this information.
Thank you for considering my perspective.
Sincerely,
Amrit Saab
