Comment Text:
Dear Chairman and Commissioners,
My name is Max Gelman, and I'm a trader and investor based in New York. I've been actively trading on prediction markets like Kalshi for a while now, and I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I strongly support the idea of well-regulated prediction markets and want to explain why I think theyre valuable, both for me personally and for society at large.
As someone who trades regularly, Ive seen firsthand how prediction markets offer insights you just cant get from polls or pundits. Ive watched these platforms predict election outcomes or economic events with a level of accuracy that often beats traditional forecasts. For example, during the last election cycle, I relied on Kalshis market data to get a clearer picture of what might happen, and it helped me make better decisions about my investments. This isnt just useful for traders like me; its valuable for anyone who needs reliable information, from business owners to everyday citizens trying to understand the world.
I also believe strongly in the freedom to participate in legal, regulated markets. Platforms like Kalshi, which operate under CFTC oversight, provide a safe and transparent environment for trading event contracts. Ive compared this to some of the unregulated offshore platforms out there, and the difference is night and day. On a regulated market, I know there are rules in place to protect me from fraud or manipulation. If we over-restrict or ban these markets, people like me will get pushed to less safe, offshore alternatives where theres no accountability. Thats not a solution; its a bigger problem.
Id like to address a couple of specific questions from the ANPR that relate to my concerns. On Question 7, regarding the balance between innovation and consumer protection, I think regulated prediction markets strike that balance well. They allow innovation in how we aggregate information while still having safeguards. And on Question 15, about defining legitimate markets versus gaming, Id argue that trading on events like elections or economic indicators isnt gambling. It takes research and judgment, just like any other investment I make.
I understand there are concerns about things like insider trading or manipulation, but I dont think the answer is to shut down these markets. The CFTC already has tools to tackle bad actors, and those should be enforced rather than punishing everyone by restricting access. Banning prediction markets would be like closing the stock market over a few insider trades. It doesnt make sense.
I urge you to support proportionate regulation of prediction markets. Keep platforms like Kalshi accessible to traders like me, with clear rules to prevent abuse, but dont over-restrict or ban them. Theyre a valuable tool, and with the right oversight, they can thrive safely.
Sincerely,
Max Gelman
