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Comment for Proposed Rule 91 FR 12516

  • From: Rachel Calimer
    Organization(s):

    Comment No: 116613
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Rachel Calimer, and Im a trader and investor from Maryland. Im also a strategy consultant, business owner, and volunteer with a background in international marketing and education. Ive worked as a high school teacher during a historic shift in the College Boards AP CSP exam due to AI advancements like ChatGPT, and Ive interned with the U.S. Office of Personnel Management and USNA Athletics Marketing. As a young person hoping for a better future, Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi, and I believe these markets offer unique value to individuals and society.


    Prediction markets arent just a niche interest for me; they provide information I cant get anywhere else. Ive seen firsthand how their forecasts on elections and public events consistently outperform polls and pundits. That accuracy isnt just helpful for traders like me, its a public good for decision-making and price discovery. Beyond that, these markets let me hedge real financial risks tied to my business and personal finances. Whether its an election outcome impacting tax policy or a Fed decision affecting interest rates, I can protect myself in ways traditional markets dont always allow. This isnt gambling. It takes research and judgment, just like trading stocks or commodities. Classifying event contracts as gaming ignores their legitimate economic purpose.


    I also value the freedom to participate in legal, regulated markets like Kalshi. Their transparency with odds and payouts stands out compared to other digital platforms Ive encountered. Regulated markets are far safer than offshore alternatives, where theres no oversight. If the CFTC bans or over-restricts prediction markets, activity will just move to those less safe venues. The U.S. should be leading in financial innovation, not ceding ground to other countries. Kalshi is taking this seriously and has the potential to help everyday Americans in ways the stock market never could. Frankly, I question why prediction markets are under such quick scrutiny when similar platforms like sports betting or even the stock market arent held to the same standard. Is this really about protection, or who benefits from regulation?


    Addressing specific concerns in your ANPR, like those in Questions 7-14 on public interest and Questions 29-32 on insider trading, I believe the CFTC already has robust tools to tackle manipulation and abuse. Insider trading is illegal, and your existing authority can handle bad actors without punishing the rest of us. Informed trading actually improves price discovery, benefiting everyone. Targeted, proportionate regulation for specific risks is far better than broad bans, as noted in Questions 33-40 on classification and costs. Lets not rush impulsive legislation without understanding the consequences.


    I urge the CFTC to support well-regulated prediction markets with clear, fair rules that protect consumers while fostering innovation. Thank you for considering my perspective, and I submit this with all due respect to all parties involved.


    Sincerely,

    Rachel Calimer

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