Comment Text:
Dear Chairman and Commissioners,
My name is Ivan Garza, and I'm a trader and investor based in California. I've been actively trading on prediction markets like Kalshi for a while now, and I'm writing to express my strong support for proportionate regulation of these markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe prediction markets provide unique value to people like me and to society as a whole, and I hope the CFTC will craft rules that allow them to thrive under proper oversight.
As a trader, I rely on prediction markets for information that I can't find anywhere else. The prices on these platforms often reflect a clearer picture of future events than polls or pundits. This isn't just useful for my own decisions, it also helps the public and even policymakers understand what's likely to happen, whether it's an election outcome or an economic indicator. I think of it as a tool for better decision-making, not just for me but for everyone. Plus, participating in these markets feels like a way to engage with real-world events, using research and judgment, much like I do with stocks or other investments.
I want to address a couple of concerns head-on. First, I know some worry that event contracts are just gambling. I strongly disagree. Trading on Kalshi, for instance, isn't about luck, it's about analyzing data and making informed calls on things like inflation numbers or policy changes. These contracts serve real economic purposes, like price discovery and even hedging against uncertainty that affects my finances. Classifying them as "gaming" would be a mistake, as it ignores their legitimate value. Second, I'm aware of fears about manipulation or insider trading. But the CFTC already has tools to tackle bad actors, and banning or over-restricting these markets isn't the answer. It would just punish honest participants like me.
On specific topics from your ANPR, Id like to touch on Questions 7 and 15, about public interest and defining gaming. I believe regulated markets like Kalshi are in the public interest because they keep activity transparent and safe, unlike unregulated offshore platforms where there's no oversight. If you push too hard with restrictions, people will just go to those riskier venues, and that's worse for everyone. Also, event contracts shouldn't be lumped in with gaming, theyre a different beast with real utility.
I urge the CFTC to support prediction markets with fair, targeted rules that address specific risks without shutting down access for regular traders like me. Freedom to participate in legal, regulated markets is important, and I hope youll prioritize innovation and public benefit over blanket restrictions. Thank you for considering my perspective.
Sincerely,
Ivan Garza
