Comment Text:
Dear Chairman and Commissioners,
My name is Shivaan Patel, and I'm a student from Indiana. 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 strongly support the idea of well-regulated prediction markets. I believe they provide real value, not just to me but to society as a whole, and I hope the CFTC will craft rules that encourage their growth rather than restrict them.
As a student, I find prediction markets fascinating because they offer insights you can't get from news or polls. I've used Kalshi to trade on events like election outcomes and economic indicators, and it's helped me understand how public events tie into real-world impacts. This isn't gambling, in my view. It takes research and critical thinking to make informed trades, much like investing in stocks. These event contracts serve a genuine economic purpose, whether it's for price discovery or even hedging against uncertainties that affect my future, like policy changes impacting student loans or job markets. Labeling them as gaming feels like a misstep when theyre so clearly tied to real economic decision-making.
What concerns me most is the risk of pushing activity to unregulated offshore platforms if the CFTC over-restricts these markets. I've traded on Kalshi because it's regulated, transparent, and based in the US. I trust that the CFTC's oversight helps protect users like me from fraud or manipulation. But if prediction markets face heavy restrictions here, people will just turn to offshore sites with no oversight. Thats far riskier for everyone. I'd much rather see the CFTC focus on strengthening regulated platforms to keep activity safe and accountable.
I also want to address a few of the specific questions in the ANPR. On Question 7, about balancing innovation and consumer protection, I think supporting regulated markets like Kalshi strikes that balance. They foster innovation by letting regular people participate in price discovery while still having safeguards in place. And on Question 15, regarding defining gaming versus legitimate markets, I believe event contracts are distinct from gambling because theyre rooted in real-world outcomes and require informed analysis, not just luck.
I know there are valid concerns about things like insider trading or manipulation. But those issues are already illegal, and the CFTC has the tools to enforce against bad actors without banning entire markets. Shutting down prediction markets to stop a few bad players would hurt students like me who use them responsibly.
I urge the CFTC to support proportionate regulation of prediction markets. Please don't impose broad bans or overly restrictive rules that could push activity to unsafe platforms. Focus on targeted protections to ensure these markets remain a valuable tool for people like me. Thank you for considering my perspective.
Sincerely,
Shivaan Patel
