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Comment for Proposed Rule 91 FR 12516

  • From: Nicholas Sands
    Organization(s):

    Comment No: 117088
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Nicholas Sands, and I'm a trader and investor from Utah. I've been actively trading on prediction markets like Kalshi for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the idea of well-regulated prediction markets, and I want to share why I think the CFTC should encourage these platforms with fair rules, not heavy-handed restrictions or bans.


    As someone who trades regularly, I value the freedom to participate in legal, regulated markets like Kalshi. These platforms aren't just a hobby for me; they're a way to engage with real-world events and make informed decisions based on research and judgment. I spend time digging into data, reading news, and weighing probabilities, just like I do with stocks or other investments. To me, calling event contracts "gaming" feels off. They're not gambling; they serve real economic purposes like price discovery and hedging. Ive used them to gauge risks tied to economic policies that could affect my investments. That's not a game, it's a tool.


    I'm worried that banning or over-restricting prediction markets will push activity to unregulated offshore platforms. I've seen what those look like, shady sites with no oversight, no consumer protections, and no accountability. Regulated markets like Kalshi are far safer. They have rules, transparency, and the CFTC watching over them. If you clamp down too hard, you're not protecting people like me; you're driving us to riskier places. This is America, the land of the free. Let's keep it free by giving us safe, legal options to participate in these markets.


    I also believe the US should lead in financial innovation. We shouldn't be playing catch-up with other countries that are already embracing prediction markets. If we stifle this space with overly strict rules, we're handing the future to someone else. I'd like to see the CFTC address specific risks without throwing out the whole concept. For instance, regarding your questions 15 to 22 on listed activities, I urge you not to classify event contracts broadly as gaming. Focus on their economic value instead. And on questions 7 to 14 about public interest, consider how regulated markets balance innovation with safety better than offshore alternatives.


    I appreciate the CFTC seeking input on this. Prediction markets matter to traders like me, and they can benefit society with better information and fair access. Please support proportionate regulation that keeps these markets legal, safe, and open to everyday Americans. Don't let heavy restrictions or bans push us into the shadows.


    Sincerely,

    Nicholas Sands

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