Comment Text:
Dear Chairman and Commissioners,
My name is Amish De, and I'm a trader and investor from California with a background in science. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the freedom to participate in legal, regulated prediction markets. However, I also have some concerns about how certain aspects are handled, and I hope the CFTC can investigate these issues while crafting fair rules.
As a scientist, I value data and transparency, and I see prediction markets as a unique way to aggregate information that isn't available through polls or expert opinions. I've used Kalshi to trade on various events, and I believe these markets need to be investigated, especially the "daily temperature" bets. I see this as almost gambling in the traditional sense. It requires research, analysis, and judgment, much like trading stocks or commodities. Banning or over-restricting these markets would cut off regular people like me from participating, which I think is unfair. Big institutions shouldn't be the only ones with access to this kind of information.
That said, I do have reservations about how some platforms operate. Specifically, I'm troubled by Kalshi's handling of weather-based contracts, like daily city temperature betting. The National Weather Service data used to settle these contracts isn't equally accessible to all participants, and I've noticed odd rounding errors in the final reported temperatures. It doesn't sit right with me, and I urge the CFTC to investigate Kalshi for fairness and transparency in how they source and report this data. This kind of issue makes me question whether some of these contracts are more like gambling than legitimate markets.
Regarding the questions posed in the ANPR, I want to address a few from Topic Area C, like Question 15 on defining gaming versus legitimate markets. I believe the CFTC should focus on transparency and equal access to data rather than labeling entire categories as gaming. Also, in response to Question 7 under Public Interest, I think innovation should be encouraged, but not at the expense of consumer protection. Proportionate regulation, targeting specific risks like manipulation or unfair data practices, is the way to go. Broad bans punish honest participants like me and push trading to unregulated offshore platforms, which helps no one.
In closing, I ask the CFTC to support well-regulated prediction markets with targeted rules that address specific issues, rather than imposing heavy-handed restrictions. Please also look into platforms like Kalshi to ensure fair practices. Thank you for considering my input.
Sincerely,
Amish De
