Comment Text:
Dear Chairman and Commissioners,
My name is Dal Nyakundi, and I'm a trader and investor based in North Carolina. 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 platforms like Kalshi and Polymarket, and I strongly support the development of well-regulated prediction markets in the United States.
As someone who navigates financial markets daily, Ive found prediction markets to be a unique tool for hedging personal and business risks. For example, Ive used these platforms to offset potential impacts from election outcomes that could affect my tax planning or investment strategies. This isnt gambling, its a legitimate way to manage uncertainty, much like trading futures or options on commodities. Classifying event contracts as "gaming" ignores their real economic purpose, whether its price discovery or risk management. I urge the CFTC to recognize this distinction, especially in response to questions 15 through 22 on listed activities.
I also believe regulated markets, like Kalshi operating under CFTC oversight, are far safer than unregulated offshore platforms. If we over-restrict or ban these markets, activity will just move to less secure venues outside US jurisdiction. Thats not protecting anyone. Instead, the US should lead in financial innovation. We shouldnt cede this space to other countries. This ties directly to questions 7 through 14 on public interest, where innovation must be balanced with consumer protection. I think proportionate regulation achieves that balance better than broad bans.
On the issue of manipulation or insider trading, raised in questions 29 through 32, Ill point out that the CFTC already has strong tools to address these risks in other derivatives markets. Use those tools here too. Dont punish honest traders like me by shutting down entire markets over a few bad actors. Also, informed trading isnt a flaw, its a feature. When knowledgeable participants trade, prices become more accurate, and that benefits everyone, not just those in the market.
Im all for rules that target specific risks, but categorical prohibitions or overly tight restrictions would hurt regular people like me who use these markets responsibly. Lets focus on smart, tailored regulation instead. I hope the CFTC will support the growth of prediction markets under a fair framework that keeps the US competitive and protects participants through oversight, not bans.
Thank you for considering my perspective.
Sincerely,
Dal Nyakundi
