Comment Text:
Dear Chairman and Commissioners,
My name is Alvaro Del Carmen, and I'm an everyday citizen from California. I'm 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 believe these markets are incredibly valuable, both for me personally and for society as a whole. I urge you to support proportionate regulation of prediction markets rather than imposing bans or overly strict rules.
I rely on prediction markets for information that I just can't get from polls or pundits. Time and again, these markets have proven to be more accurate in forecasting events like elections or economic shifts. That better information helps me make decisions in my own life, and I think it could benefit public decision-making too if more people had access to it. Plus, trading on these platforms isn't gambling in my view. It takes research and real-world judgment, much like investing in stocks. Classifying event contracts as "gaming" feels wrong when they serve legitimate purposes like price discovery and risk management.
I'm also worried about what happens if the CFTC over-restricts or bans these markets. I've seen unregulated offshore platforms out there, and they're nowhere near as safe as a regulated market like Kalshi. If you push activity offshore, you're not stopping the money flow; you're just losing oversight and tax revenue. Look at the illegal sports books all over the place. No regulation, no data, no taxes going to the government. The CFTC would be costing the government a lot of money by driving prediction markets underground. I believe the U.S. should lead in financial innovation, not cede that space to other countries with looser rules.
On specific concerns like manipulation or insider trading, I think the CFTC already has strong tools to address bad actors. You don't need broad bans; you need targeted enforcement of existing laws. And honestly, informed trading often improves price discovery, which benefits everyone in the market, not just the traders. I'm particularly drawn to your questions 7 and 8 in the Public Interest section about balancing innovation with consumer protection, and question 15 on defining gaming versus legitimate markets. I hope you'll consider how regulated prediction markets can drive innovation and provide real economic value, far beyond what some might call gambling.
I strongly support a framework that regulates proportionately. Address specific risks with focused rules, not categorical restrictions that punish everyone. Please keep prediction markets accessible and safe under CFTC oversight, and don't let them slip into the shadows offshore.
Thank you for considering my perspective.
Sincerely,
Alvaro Del Carmen
