Comment Text:
Dear Chairman and Commissioners,
My name is Julian Cortez, and I'm a student based in Hawaii. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on regulated platforms like Kalshi, I strongly support the development of well-regulated prediction markets in the United States. I believe they serve valuable purposes and should not face overly restrictive rules or outright bans.
I've been trading on prediction markets for a while now, mostly to gain insight into political and economic events that affect my life and studies. As a student, I don't have access to the same resources as big institutions, but platforms like Kalshi give me a chance to participate in a legal, regulated space. The information I get from market prices often feels more reliable than what I read in the news or see in polls. It's not just about making a few bucks; it's about understanding the world better. I worry that if the CFTC over-restricts these markets, regular people like me will be pushed out, and only the big players will benefit from this kind of insight.
I also want to stress that event contracts aren't gambling. When I trade on Kalshi, I'm not tossing dice or betting on a sports game. I'm researching, analyzing data, and making informed decisions about real-world events, just like someone trading stocks or commodities. Classifying these contracts as "gaming," as discussed in Questions 15-22 of the ANPR, misses their real economic purpose. They help with price discovery and even let people hedge against uncertainties, like policy changes that could impact my future career or loans.
Another concern I have is what happens if these markets are banned or heavily restricted. I've seen unregulated offshore platforms out there, and they're far riskier, with no consumer protections. If the CFTC makes it too hard to operate legally in the US, activity will just move to those unsafe spaces. I'd much rather see regulated markets like Kalshi thrive under clear, fair rules. This ties into Questions 7-14 on public interest, where I believe innovation and consumer protection can go hand in hand if regulation is done right.
Lastly, I think the US should be a leader in financial innovation. We shouldn't cede this space to other countries by over-regulating. As for risks like manipulation or insider trading, mentioned in Questions 29-32, I believe targeted rules and enforcement of existing laws are the answer, not broad bans that punish everyone.
I urge the CFTC to support proportionate regulation that addresses specific risks without shutting down prediction markets. Let regular people like me continue to participate in safe, legal platforms. Thank you for considering my input.
Sincerely,
Julian Cortez
