Comment Text:
Dear Chairman and Commissioners,
My name is Ian Falls, and I'm a regular citizen from Virginia 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 strongly support the idea of well-regulated prediction markets. I believe they serve a real purpose and shouldn't be treated as gambling or overly restricted.
I got into trading on prediction markets because I wanted a way to make sense of the uncertainty around big events, like elections or economic decisions, that affect my day-to-day life. On Kalshi, I can put my money behind what I think will happen, and it forces me to do my homework and really think through the odds. This isn't a slot machine or a lottery ticket. It's research and judgment, just like when I decide to invest in a stock or save for a big purchase. Classifying event contracts as "gaming" feels wrong to me because they have a clear economic purpose, whether it's hedging against risks or figuring out what the crowd thinks is most likely to happen. I urge you to consider this in your response to questions 15 through 22 about listed activities and how to define gaming versus legitimate markets.
I'm also worried about what happens if the CFTC over-restricts or bans these markets. I've seen unregulated offshore platforms out there, and they're nowhere near as safe or transparent as a regulated market like Kalshi. If you make it too hard to trade on legitimate platforms, people like me will get pushed to those shadier options. That's not protecting anyone. It's just hiding the problem. I'd like to see you address this in questions 7 through 14 on balancing innovation and consumer protection.
Lastly, I know there are concerns about manipulation or insider trading, but aren't those already illegal? The CFTC has plenty of tools to go after bad actors in other markets, and I believe those same tools can work here. There's no need to throw out the whole concept of prediction markets just because a few might cheat. Look at questions 29 through 32 on inside information. I think the focus should be on enforcing existing rules, not creating new barriers.
I hope you'll support proportionate regulation that keeps prediction markets accessible to regular people like me while addressing real risks with targeted rules. Please don't ban or over-restrict them. Thank you for taking the time to read my comment.
Sincerely,
Ian Falls
