Comment Text:
Dear Chairman and Commissioners,
My name is Sarah Ardila, and I'm a student from Texas 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, and I believe that well-regulated prediction markets offer real value to people like me, as well as to society at large. I'm passionate about the freedom to participate in legal markets, the better information these markets provide, and ensuring the US stays competitive in financial innovation.
As a student, I've seen firsthand how prediction markets often produce more accurate forecasts than polls or pundits. When I traded on Kalshi during the last election cycle, the market prices gave me a clearer picture of what might happen than any news outlet. That kind of information isn't just useful for traders; it helps everyone make better decisions, from regular folks to policymakers. I also think these markets let people like me hedge real risks. For example, Ive used them to offset uncertainties around economic events that could impact my student loans or part-time job prospects. This isn't gambling. It takes research and judgment, just like investing in stocks.
Im also worried about what happens if we over-restrict these markets. Regulated platforms like Kalshi have safeguards in place, and I feel safer trading there than I would on some offshore site with no oversight. If the CFTC bans or heavily limits prediction markets, people will just go to those unregulated alternatives. Thats worse for consumer protection, not better. Plus, the CFTC already has strong tools to stop manipulation and insider trading in other markets. I trust those can be applied here without shutting everything down.
On the academic side, I value how these markets create transparent data for research. They aggregate information efficiently, and as someone studying in Texas, I think that informed trading actually improves price discovery for everyone. Id urge you to look at questions 7 and 29 from the ANPR, on balancing innovation with protection and the role of informed traders. I believe the benefits of accessible, regulated markets outweigh the risks, especially when the alternative is pushing activity offshore.
I also want the US to lead in financial innovation. We shouldnt let other countries take the lead on something with so much potential. Yes, there are risks like manipulation, but banning broad categories of contracts punishes honest participants like me. Instead, target the specific bad actors with the tools you already have.
I respectfully ask that the CFTC support proportionate regulation of prediction markets. Please dont ban or over-restrict them. Let students and everyday people continue to participate in these valuable, regulated spaces.
Sincerely,
Sarah Ardila
