Comment Text:
Dear Chairman and Commissioners,
My name is Charles Concodora, and I'm a trader and investor from the United States. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and I'm writing to express my strong support for well-regulated prediction markets in response to your Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to people like me, and I want to share my perspective.
As someone who trades regularly, I've seen firsthand how prediction markets aren't just a game or a gamble. They're a tool for understanding the world and managing risk. For example, I've used event contracts on Kalshi to hedge personal financial risks tied to economic indicators like inflation data. When I'm worried about how a CPI report might affect my investments or costs, trading on a prediction market lets me offset some of that uncertainty. This isn't betting; it's a calculated decision based on research and judgment, much like trading stocks or futures. Classifying these contracts as "gaming" feels wrong when they serve such clear economic purposes.
I also want to stress how important it is to keep these markets regulated here in the US. Platforms like Kalshi, which operate under CFTC oversight, are transparent and accountable. I've traded on unregulated offshore platforms like Polymarket too, and the difference is night and day. Without regulation, there's no real protection against fraud or manipulation. If the CFTC over-restricts or bans these markets, people like me won't stop trading; we'll just get pushed to less safe, offshore options. That's not a solution. It's a step backward.
On top of that, prediction markets help regular folks and businesses manage real risks. Beyond my personal hedging, I know small business owners who watch these markets to gauge political or regulatory outcomes that could hit their bottom line. This isn't gambling; it's practical. And the US should be leading the way in this kind of financial innovation. If we clamp down too hard, other countries will take the lead, and we'll lose out on the economic benefits and the chance to set global standards.
I'd like to address a couple of specific questions from your ANPR. On Question 15, about defining gaming versus legitimate markets, I urge you to focus on the economic purpose of event contracts. If they're used for hedging or price discovery, they shouldn't be lumped in with gambling. And on Question 7, about balancing innovation and consumer protection, I believe strong regulation, not prohibition, is the answer. Keep markets like Kalshi operating under clear rules, and you'll protect traders while fostering growth.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Don't ban or over-restrict them. These markets are too valuable for individuals and businesses trying to navigate an uncertain world. Thank you for considering my input.
Sincerely,
Charles Concodora
