Comment Text:
Dear Chairman and Commissioners,
My name is Wonjoon Kim, and I'm a small business owner based in Wyoming. Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on regulated platforms like Kalshi, and I strongly support the CFTC developing proportionate regulations for prediction markets rather than imposing broad restrictions or bans.
As a business owner, I deal with a lot of uncertainty, whether its changes in regulations, economic policies, or even weather events that impact my supply chain. Prediction markets have become a valuable tool for me to hedge some of these risks. For example, Ive used event contracts to offset potential losses tied to policy shifts that could hit my bottom line. This isnt gambling; its a practical way to manage real financial exposure, much like how Id use other derivatives to protect my business. I also find the price discovery aspect incredibly helpful. The aggregated information from these markets often gives me a clearer picture of whats coming than any news outlet or poll, helping me make better decisions for my company.
Im also concerned about personal freedom and fairness. I believe regular people like me should have access to these markets, not just big institutions. Platforms like Kalshi, which are regulated by the CFTC, provide a safe and transparent way to participate. If the CFTC over-restricts or bans these markets, I worry that activity will just move to unregulated offshore platforms where theres no oversight or consumer protection. Thats a much worse outcome for everyone. Keeping these markets regulated in the U.S. also ensures we stay competitive in financial innovation. We shouldnt cede leadership to other countries by driving this industry underground.
Regarding some of the specific questions in the ANPR, Id like to address Question 11 under Public Interest. Prediction markets offer unique benefits like better forecasting and risk management that outweigh the risks when properly regulated. On Question 29 under Inside Information, I believe informed trading actually improves price discovery and helps all participants by making the market more accurate. The CFTC already has tools to tackle insider trading and manipulation; those should be enforced rather than banning entire categories of contracts. Finally, on Question 15 under Listed Activities, I urge you to recognize that event contracts serve legitimate economic purposes and shouldnt be lumped in with gambling.
I understand there are concerns about manipulation or misuse, but broad bans arent the answer. Targeted rules addressing specific risks make more sense. I trust the CFTC can strike the right balance. Please support proportionate regulation of prediction markets so that small business owners like me can continue to use these tools safely and legally.
Thank you for considering my input.
Sincerely,
Wonjoon Kim
