Comment Text:
Dear Chairman and Commissioners,
My name is Yanni Kakouris, and I'm a student and academic based in Massachusetts. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi, I've seen firsthand how these markets provide unique value, and I believe the CFTC has an opportunity to foster innovation while protecting consumers through thoughtful rules.
Prediction markets aren't just a hobby for me; they offer insights I can't find anywhere else. I've used platforms like Kalshi to track election outcomes and other public events, and I'm consistently impressed by how much more accurate their forecasts are compared to traditional polls or pundits. This isn't gambling. It takes research and judgment, much like any other investment. Classifying event contracts as "gaming" ignores their real economic purpose, whether it's price discovery or helping people like me make informed decisions. I also see potential for hedging personal financial risks, like policy changes that could affect my future career or student loans. These markets give ordinary folks a chance to protect themselves, not just big institutions.
I'm particularly concerned about the risk of over-restriction or outright bans. If the CFTC clamps down too hard, activity will just move to unregulated offshore platforms, which are far less safe. I've traded on Kalshi because it's regulated, transparent, and accountable under CFTC oversight. That matters to me as a consumer. The US should be leading in financial innovation, not pushing it elsewhere. Regulated markets also produce valuable data for academic research, something I care about deeply as a student. Better information benefits everyone, from policymakers to the public, and informed trading only improves price discovery.
I want to address a few of the CFTC's specific questions. On Question 7, regarding public interest, I believe prediction markets serve the public by aggregating information efficiently and offering hedging tools. On Question 29, about inside information, I think informed traders actually help make prices more accurate, and existing laws already prohibit federal employees from misusing nonpublic data. The CFTC already has strong tools to tackle manipulation and insider trading, as noted in Questions 1 and 2. There's no need for broad bans when targeted enforcement can address bad actors without punishing everyone else.
I urge the CFTC to adopt a balanced approach. Don't ban or overly restrict prediction markets. Instead, focus on proportionate rules that address specific risks while allowing these platforms to thrive. Let's keep the US at the forefront of financial innovation and ensure consumers like me have access to safe, regulated markets.
Sincerely,
Yanni Kakouris