Comment Text:
Dear Chairman and Commissioners,
My name is Maximos Papageorge-Martinez, and I'm a student and academic based in California. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I strongly support the proportionate regulation of prediction markets, and I want to share why these markets matter to me and to society.
I've found prediction markets to be incredibly valuable for understanding the world around me. Whether it's an election or a major public event, the forecasts on these platforms consistently outperform polls and pundits. As a student, I rely on accurate information to make sense of complex issues, and prediction markets give me insights I can't get elsewhere. Beyond that, they allow me to hedge personal financial risks. For example, trading on election outcomes helps me think through how policy changes might impact my future career or student loans. This isn't gambling, it's a practical tool for managing uncertainty, much like any other investment.
I also value the freedom to participate in legal, regulated markets. Platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore alternatives. If the CFTC over-restricts or bans these markets, activity will just shift to less transparent venues where consumer protections are nonexistent. I'm concerned about that outcome, and I believe the CFTC should focus on regulation, not prohibition. The US has a chance to lead in financial innovation here, and we shouldn't cede that to other countries.
Regarding some of your specific questions, like those in Topic Area B on public interest (Questions 7-14), I believe prediction markets serve the public by improving price discovery and helping individuals and businesses hedge real risks. Informed trading, as raised in Topic Area E (Questions 29-32), actually benefits everyone by making prices more accurate. And to address concerns about manipulation or insider trading, I want to point out that the CFTC already has strong tools to tackle these issues. There's no need for broad categorical bans when targeted rules can address specific risks, as discussed in Topic Area D (Questions 23-28). Finally, event contracts shouldn't be classified as gaming. They serve legitimate economic purposes, unlike pure chance-based activities.
I urge the CFTC to support well-regulated prediction markets with rules that protect consumers while preserving access. Banning or over-restricting these markets would harm people like me who use them responsibly, and it would push activity to unsafe offshore platforms. Please prioritize proportionate regulation that keeps the US at the forefront of innovation.
Thank you for considering my input.
Sincerely,
Maximos Papageorge-Martinez
