Comment Text:
Dear Chairman and Commissioners,
My name is Dhruv Tomar, and I'm a student based in Michigan with a strong interest in economics and financial markets. I've been actively trading on prediction market platforms like Kalshi and Polymarket for the past couple of years, and Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the development of well-regulated prediction markets in the United States, and Id like to share why I think they are valuable for people like me, as well as for society at large.
As a student, I dont have a huge income, but Ive found prediction markets to be a unique way to engage with real-world events and even hedge some personal financial risks. For instance, trading on contracts tied to inflation data or interest rate decisions helps me think through how those outcomes might affect my student loans or future job prospects. Beyond my own situation, Ive seen firsthand how these markets often predict outcomes more accurately than polls or media pundits. During the last election cycle, platforms like Kalshi got closer to the actual results than most surveys I read. That kind of information isnt just useful for traders; its valuable for the public and even policymakers who need reliable forecasts.
I also believe that regulated prediction markets are far safer than the alternative. Ive used both Kalshi, which operates under CFTC oversight as a designated contract market, and offshore platforms like Polymarket. The difference in transparency and accountability is night and day. If the CFTC over-restricts or bans these markets, people like me wont stop trading; well just move to unregulated offshore sites where theres less protection. Id much rather see the US lead in financial innovation by creating a strong regulatory framework here at home.
Addressing some of the specific questions in the ANPR, I think the CFTCs existing tools for preventing manipulation and insider trading are already robust and can be applied to prediction markets without sweeping bans (relevant to Questions 1-6 on core principles). I also believe these markets serve the public interest through better price discovery and risk management, as raised in Questions 7-14. Finally, on the topic of where activity might go if over-regulated (Questions 33-40 on costs and benefits), I urge you to consider how bans could push trading offshore, hurting US competitiveness.
I understand there are concerns about manipulation or misuse, but shutting down entire markets isnt the answer. Punishing everyone for the actions of a few bad actors doesnt make sense when the CFTC already has the authority to tackle fraud and insider trading. I hope youll support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules.
Thank you for considering my perspective. Im excited about the potential of these markets and want to see them grow under fair oversight.
Sincerely,
Dhruv Tomar
