Comment Text:
Dear Chairman and Commissioners,
My name is Tadeh Grigorian, and I'm a trader and investor based in California. I also run a small business here, and Ive been actively trading on prediction markets like Kalshi for a while now. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to express my strong support for well-regulated prediction markets. I believe they provide unique value to people like me, and to society as a whole, and I urge the CFTC to craft rules that protect consumers without stifling this innovative tool.
As a small business owner, I rely on accurate information to make decisions about my finances and operations. Prediction markets have consistently given me better forecasts for things like election outcomes and economic events than polls or pundits ever could. Thats not just helpful for trading, its critical for planning my business moves. Beyond forecasting, I use these markets to hedge real risks. For instance, Ive traded contracts tied to economic indicators that impact my costs, like interest rate decisions that affect my loans. This isnt gambling, its a practical way to manage uncertainty, much like any other investment or derivative.
Im also concerned about the idea of over-restricting or banning these markets. Ive seen what happens when activity gets pushed to unregulated offshore platforms. Those places have no oversight, no consumer protections, and no accountability. Trading on a regulated platform like Kalshi, under CFTC supervision, is far safer. I think the CFTC already has strong tools to tackle issues like manipulation and insider trading, as seen in other derivatives markets. Use those tools, dont just shut things down. Banning or over-regulating prediction markets would punish honest traders like me and send innovation overseas. The U.S. should be leading in financial innovation, not handing that advantage to other countries.
I want to address a few specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I believe regulation is the answer, not prohibition. Protect consumers by keeping markets transparent and monitored, not by banning them. On Question 15, regarding whether event contracts are gaming, I strongly disagree with that label. These contracts serve real economic purposes like hedging and price discovery, just as futures or options do. And on Question 29, about inside information, I think the existing laws against insider trading are sufficient if enforced properly. Dont punish the market for the actions of a few bad actors.
Prediction markets arent just a niche tool for traders. They democratize information, help businesses like mine manage risk, and give regular people a stake in understanding public events. I ask the CFTC to support proportionate regulation that addresses specific risks without broad bans or restrictions. Keep these markets accessible, safe, and innovative right here in the U.S.
Thank you for considering my input.
Sincerely,
Tadeh Grigorian
