Comment Text:
Dear Chairman and Commissioners,
My name is Pablo Lechuga, and I'm a student from California writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi for a while now, and I strongly support the idea of well-regulated prediction markets. I believe they offer unique value, and I hope my perspective as a younger person engaging with these markets can help inform your approach.
As a student, I find prediction markets fascinating because they give me a way to learn about the world while putting some skin in the game. I've traded on contracts tied to economic data releases and election outcomes, and it's pushed me to dig into research and think critically about what's happening around me. This isn't just gambling, it's a process of analysis and judgment, much like investing in stocks. The prices on these markets often seem more accurate than what I read in the news or hear from pundits. That kind of information is helpful not just to me, but to anyone trying to make sense of uncertain events.
What I care about most is having the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, give me confidence that there are rules in place to prevent manipulation and ensure fairness. I've looked at some offshore, unregulated platforms out of curiosity, and they feel sketchy. There's no transparency, no accountability. If prediction markets get over-restricted or banned here, people like me won't just stop trading, we'll get pushed to those unsafe venues. I think that's a worse outcome for everyone. Regulation should keep us in a safe, supervised space, not drive activity underground.
I also want to address a concern I know the CFTC has about potential risks like insider trading, which I see in some of the questions in the ANPR, like those in Topic E (Questions 29-32). I get why that's a worry, but insider trading and market manipulation are already illegal. The CFTC has tools to enforce against bad actors in other markets, and those can work here too. Banning or over-restricting prediction markets to stop a few cheaters feels like punishing the rest of us who are playing by the rules.
In response to some of the public interest questions in Topic B (Questions 7-14), I believe regulated prediction markets balance innovation with consumer protection by letting ordinary people like me participate while having oversight to keep things fair. I urge you to focus on proportionate regulation that targets specific risks without shutting down the whole system.
Thank you for considering my input. I hope the CFTC will support well-regulated prediction markets and allow platforms like Kalshi to continue operating under clear, fair rules. Let's not push this activity offshore by over-restricting it at home.
Sincerely,
Pablo Lechuga
