Comment Text:
Dear Chairman and Commissioners,
My name is Christopher Chambers, and I'm an engineer based in California. I'm writing to share my thoughts 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 believe these markets serve a valuable purpose. I want to urge the CFTC to support well-regulated prediction markets rather than imposing bans or overly restrictive rules.
As someone who works in a technical field, I value data and evidence. Prediction markets provide unique information that I can't find elsewhere, whether it's about election outcomes or economic indicators. They're not just a game to me; they require research and judgment, much like any other investment. I use these markets to make informed decisions, and I know others do too. Calling event contracts "gaming" feels wrong when they serve real economic purposes like hedging risks or understanding market sentiment. I worry that labeling them as gambling could unfairly limit access for regular people like me.
I'm also concerned about what happens if these markets are over-restricted or banned. I've seen unregulated offshore platforms out there, and they're far riskier than a regulated market like Kalshi. If the CFTC makes it too hard to trade on legitimate, U.S.-based platforms, people will just turn to those sketchy alternatives. That doesn't protect consumers; it puts us in harm's way. Regulation should focus on keeping markets safe and transparent, not pushing activity out of sight.
I appreciate that the CFTC is asking for input on balancing innovation with consumer protection, as raised in questions 7 through 14 of the ANPR. I believe the answer lies in targeted rules, not broad prohibitions. For instance, address specific risks like manipulation with the tools you already have, rather than banning entire categories of contracts. Questions 15 through 22 about defining "gaming" also hit close to home. These contracts aren't lotteries; they're based on real-world events and informed analysis. Treating them as gambling would misunderstand their purpose.
I also want to touch on the freedom to participate in legal, regulated markets. As an engineer, I solve problems for a living, and I bring that same mindset to trading. Prediction markets let me engage with the world in a meaningful way. Shutting down access for everyday folks while big institutions might still find loopholes feels unfair and counterproductive.
In closing, I ask the CFTC to adopt proportionate regulations that keep prediction markets accessible, safe, and transparent. Don't let overly harsh rules push activity offshore or misclassify these contracts as gambling. I'm happy to provide more input if needed, and I thank you for considering my perspective.
Sincerely,
Christopher Chambers
