Comment Text:
Dear Chairman and Commissioners,
My name is Dominik Robak, and Im a business owner from Minnesota. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I strongly support the development of well-regulated prediction markets in the United States. I believe they provide unique value to individuals like me, to businesses, and to society as a whole.
As a business owner, I deal with uncertainty every day, whether its regulatory changes, economic shifts, or political events that could impact my operations. Prediction markets give me a tool to hedge some of those risks. For instance, Ive used platforms like Kalshi to trade on election outcomes that could affect tax policies or local regulations impacting my business. This isnt gambling. Its a practical way to manage real-world exposure, much like trading futures to lock in commodity prices. Ive also found the data from these markets to be incredibly useful, often more accurate than polls or media predictions. That kind of transparency and price discovery helps me make better decisions, and I believe it benefits the public too.
Im aware of concerns about manipulation or insider trading, and I get why those are issues to watch. But the CFTC already has strong tools to tackle these problems in other markets, and they can apply those same safeguards here. Banning or overly restricting prediction markets doesnt solve anything. It just pushes activity to unregulated offshore platforms, which are far less safe and lack oversight. Id much rather trade on a regulated U.S. platform like Kalshi, where theres accountability, than take my chances elsewhere. Plus, academic research backs this up. Studies by economists like Hanson and Wolfers show that informed trading actually improves price discovery, benefiting everyone, not just traders.
Id like to address a couple of specific questions from the ANPR. On Question 8, regarding public interest, I believe prediction markets serve a clear public good through better forecasting and risk management. On Question 15, about defining gaming versus legitimate markets, I strongly feel event contracts arent gambling. They serve economic purposes like hedging and information aggregation, just as stock or commodity trading does. And on Question 29, about inside information, I think informed traders often enhance market accuracy, as long as existing laws against insider trading are enforced.
The U.S. has a chance to lead in financial innovation with prediction markets. We shouldnt cede that to other countries by over-regulating or imposing broad bans. I urge the CFTC to adopt proportionate, targeted rules that address specific risks without shutting down these valuable tools. Lets keep markets like Kalshi accessible to everyday people and businesses while ensuring strong oversight.
Thank you for considering my input.
Sincerely,
Dominik Robak
