Comment Text:
Dear Chairman and Commissioners,
My name is Adam Samples, and I'm a high school teacher from Kentucky. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As a middle-class citizen, I actively trade on prediction markets like Kalshi to supplement my income, moving any profits into traditional investment accounts to build toward a comfortable retirement. I strongly support well-regulated prediction markets and hope to continue participating in them for years to come.
When I decided to include prediction markets in my trading strategy, I had a choice between Kalshi, a regulated U.S. entity, and unregulated offshore competitors. I chose Kalshi because of the safety and trust that comes with regulation. Banning or over-restricting these markets would push people like me toward less safe, unregulated platforms. I don't think that's the answer.
I also want to stress that event contracts are not gambling. Trading on Kalshi requires research and judgment about real-world events, much like investing in stocks. Classifying these as "gaming" doesn't make sense when they serve legitimate economic purposes like price discovery and hedging. I urge the CFTC to consider this when addressing questions 15 through 22 on listed activities. These contracts aren't just games; they're tools for people to manage uncertainty or gain insight.
Another concern of mine is U.S. leadership in financial innovation. If we over-regulate or shut down prediction markets, we're handing the future of this technology to other countries. I'd rather see the U.S. lead the way with smart, proportionate rules that protect consumers without stifling opportunity. This ties into questions 7 through 14 on public interest, where I believe the balance should favor innovation while ensuring safety through oversight.
I know there are worries about things like insider trading or manipulation. But as a trader, I accept that risk is part of the game. You can't regulate away every possible unfair advantage, and existing laws already ban insider trading and market manipulation. The CFTC has tools to handle bad actors without punishing everyone else. Let's not throw out a useful market just because a few might cheat.
I'm asking the CFTC to support proportionate regulation of prediction markets. Keep them legal and accessible on regulated platforms like Kalshi, where there's oversight and accountability. Don't let heavy-handed restrictions push activity offshore to riskier venues. Thank you for considering my perspective as an everyday citizen who values this opportunity.
Sincerely,
Adam Samples
