Comment Text:
Dear Chairman and Commissioners,
My name is Ignacio Bembhy, and I'm a student from Florida with a strong interest in economics and public policy. I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I want to express my support for well-regulated prediction markets and urge the CFTC to adopt a balanced, proportionate approach to their oversight.
I've found prediction markets to be an incredible tool for understanding real-world events. Trading on Kalshi has taught me to research, analyze data, and think critically about everything from election outcomes to economic indicators. This isn't gambling, not by a long shot. It takes skill and judgment, just like investing in stocks or futures. Classifying event contracts as "gaming," as discussed in Questions 15-22 of the ANPR, ignores their real economic purpose. They're about price discovery and hedging, not just betting for fun. For me, trading on these markets has been a way to engage with issues that matter, and I believe the information they generate helps everyone, from policymakers to regular citizens, make better decisions.
I'm also concerned about preserving access to these markets for people like me, students and everyday folks, who want to participate in a legal, regulated space. Banning or over-restricting prediction markets, as some past proposals suggested, would push activity to unregulated offshore platforms. The U.S. should be leading in financial innovation, not ceding ground to other countries. Regulated markets like Kalshi are transparent and safe, and they keep activity under the CFTC's watch. I think the CFTC already has strong tools to handle risks like manipulation and insider trading, as touched on in Questions 1-6 and 29-32. There's no need for broad bans when targeted rules can address specific problems.
On the academic side, I'm fascinated by how prediction markets aggregate information. Research shows they often outperform polls and pundits, and I believe informed trading, far from being a problem, actually improves price discovery for everyone's benefit. Questions 29-32 ask about insider information, and I think the focus should be on enforcing existing laws against abuse, not punishing the whole market. Shutting down these platforms to stop a few bad actors makes no sense. It's like closing the stock market over insider trading scandals.
I hope the CFTC will support proportionate regulation that keeps prediction markets accessible and innovative. Don't let broad categorical restrictions stifle a tool that educates, informs, and empowers people like me. I'm excited to see the U.S. lead in this space, and I trust the CFTC can find the right balance.
Thank you for considering my input.
Sincerely,
Ignacio Bembhy
