Comment Text:
Dear Chairman and Commissioners,
My name is Gianni Esparza, and I'm just a regular citizen from Texas 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 real value to people like me and to society as a whole, and I hope the CFTC will craft rules that allow these markets to thrive without over-restricting them.
I first got into prediction markets because I wanted a better way to understand what's happening in the world. Polls and pundits often get things wrong, but the prices on these markets seem to cut through the noise. They've consistently been more accurate on things like election outcomes or economic indicators, and that's information I can't find anywhere else. As an everyday person, I value having access to this kind of insight. It's not just for traders; it helps anyone paying attention make better decisions.
I also want to stress that these markets aren't gambling, no matter what some might say. Trading on Kalshi takes research and judgment, just like investing in stocks. I'm not rolling dice; I'm analyzing real-world events. These event contracts serve a real purpose, whether it's hedging against uncertainty or gaining clarity on future outcomes. Classifying them as "gaming" feels unfair and misses the point of their economic value. I hope the CFTC considers this when addressing questions like 15 and 16 on listed activities.
Another thing that worries me is the idea of banning or heavily restricting these markets. If that happens, people won't just stop trading; they'll move to unregulated offshore platforms where there's no oversight. I've seen how Kalshi operates under CFTC rules, and it feels safe and transparent. Pushing activity overseas would be a step backward, and it would hurt regular folks like me who want to participate legally. On top of that, the US should be leading in financial innovation, not letting other countries take the wheel. I think questions 7 and 8 in the ANPR, about balancing innovation and public interest, get at this concern.
Lastly, I'm confident the CFTC already has the tools to handle issues like manipulation or insider trading. Those things are already illegal, and the Commission has the power to enforce the rules. Instead of broad bans, I'd urge you to focus on targeted, proportionate regulations that address specific risks without shutting down entire markets. This ties into questions 29 through 32 on inside information and how to manage those challenges.
I appreciate the chance to weigh in. Please support rules that let prediction markets grow under fair oversight. Don't ban or over-restrict them. We need access to these tools, and the US should be at the forefront of this space.
Sincerely,
Gianni Esparza
