Comment Text:
Dear Chairman and Commissioners,
My name is Dennis Karganilla, and I'm a small business owner from California. Im 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 regulated prediction markets like Kalshi, and I strongly support the CFTC creating a fair, proportionate regulatory framework for these markets rather than imposing heavy restrictions or outright bans.
Running a business means Im always dealing with uncertainty, whether its economic shifts, policy changes, or even local regulations that impact my bottom line. Trading on Kalshi has given me a way to hedge some of that risk and get a clearer picture of what might happen next. The information these markets provide isnt just useful to me; its valuable to anyone trying to make informed decisions. Ive found the prices on prediction markets often cut through the noise of polls or news spin, and thats something worth protecting.
What worries me is the idea of over-restricting or banning these markets. I choose to trade on a regulated platform like Kalshi because its safer and more transparent than the unregulated offshore alternatives out there. If the CFTC clamps down too hard, people like me will get pushed toward those less safe venues. Thats not protecting consumers; its putting us at greater risk. Id rather see the U.S. take the lead on financial innovation and set a global standard for how these markets should work, instead of ceding that ground to other countries.
I also dont think event contracts should be lumped in with gaming. Trading on these markets isnt a game of chance. It takes research and judgment, much like any other investment. These contracts serve real economic purposes, like helping me manage risk tied to political or economic events that affect my business. Addressing specific CFTC questions, like those in Topic Area C (Questions 15-22), I urge you to define these markets based on their legitimate uses, not mischaracterize them as gambling.
Finally, I believe the CFTC should focus on targeted rules to address real risks, such as manipulation or insider trading, rather than broad categorical bans. As raised in Topic Area D (Questions 23-28), lets evaluate contracts based on their individual merits, not sweep whole categories off the table. Proportionate regulation will keep markets fair and accessible while tackling bad actors without punishing the rest of us.
I respectfully ask the CFTC to support a balanced regulatory approach for prediction markets. Lets keep them legal, accessible, and well-regulated right here in the U.S.
Sincerely,
Dennis Karganilla
