Comment Text:
Dear Chairman and Commissioners,
My name is Sam Goin, and I'm a student from California. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi for a while now, and I strongly support the development of well-regulated prediction markets. I believe they provide unique value to society and to people like me who want to engage with the world in a meaningful way.
As a student, I spend a lot of time studying data, trends, and public events. Prediction markets have been an incredible tool for me to test my understanding of what's happening, whether it's an election outcome or a major policy decision. I've noticed that the forecasts on these platforms are often more accurate than polls or pundit opinions you see on TV. For instance, during the last election cycle, I saw Kalshi's market prices predict results closer to the actual outcome than most national surveys. This isn't just useful for traders; it helps everyone by providing clearer information about the future. I think this ties directly to your questions on public interest, like Question 7, about balancing innovation with consumer protection. The innovation here is real, and it benefits the public by improving how we understand complex events.
I also want to stress that event contracts aren't gambling. They're based on research and informed judgment, much like trading stocks or commodities. I put time into reading up on issues before placing a trade, and I feel this is a legitimate way to participate in markets. Banning or over-restricting these contracts, as some might suggest, would push people like me to unregulated offshore platforms. Those places have no oversight, no consumer protections, and no accountability. I'd much rather trade on a CFTC-regulated platform like Kalshi, where I know there are rules in place. This relates to your Question 15 on defining gaming versus legitimate markets. These markets serve a real economic purpose, like price discovery, and shouldn't be lumped in with gambling.
Lastly, I believe informed trading makes markets better for everyone. When people with good information participate, the prices reflect reality more accurately. This isn't something to fear; it's a strength. Regarding your Question 29 on inside information, I think the focus should be on enforcing existing laws against insider trading, not shutting down entire markets. Punishing everyone for the actions of a few bad actors doesn't make sense to me.
I urge the CFTC to support proportionate regulation of prediction markets. Don't ban or overly restrict them. Allow platforms like Kalshi to operate under clear, fair rules that protect consumers while preserving access for regular people like me. Thank you for considering my perspective.
Sincerely,
Sam Goin
