Comment Text:
Dear Chairman and Commissioners,
My name is Exequiel Punzalan, and I'm just an everyday citizen from New Jersey writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I've used prediction markets a few times myself, and I believe they have real value for people like me and for society as a whole. I want to urge the CFTC to support well-regulated prediction markets with proportionate rules, not bans or overly tight restrictions.
Ive seen firsthand how prediction markets can cut through the noise of polls and pundits. During the last election cycle, I checked platforms like Kalshi to get a sense of what might happen, and their forecasts were often sharper than anything on TV or in the news. That kind of information isnt just useful for traders; it helps regular people make sense of public events. Its not gambling, either. When I trade on these platforms, Im researching and thinking hard about real-world outcomes, just like I would with stocks or other investments. Classifying event contracts as "gaming" feels wrong to me because they serve a real economic purpose, like price discovery and even hedging against uncertainty.
I also worry that banning or over-restricting these markets would push activity to unregulated offshore platforms. Id much rather trade on a regulated U.S. market like Kalshi, where there are consumer protections in place, than take my chances with some sketchy foreign site. The CFTC already has strong tools to tackle issues like manipulation and insider trading in other markets. I believe those same tools can work here without throwing out the whole concept of prediction markets. Plus, informed trading actually helps everyone by making prices more accurate, reflecting better information for public decision-making.
Im also concerned about the U.S. falling behind. We should be leading in financial innovation, not letting other countries take the wheel. Overly harsh rules would just cede that ground. I think the CFTC should focus on targeted regulations to address specific risks, not broad categorical bans that punish everyone. For instance, regarding your questions 7 and 8 on public interest, I believe prediction markets balance innovation with public good by providing unique data. And on question 29 about inside information, I think informed traders often improve price discovery, as long as existing laws against insider trading are enforced.
Prediction markets give regular folks like me a chance to participate in something meaningful, and they produce insights we cant get elsewhere. I ask the CFTC to regulate them fairly and proportionately, keeping them accessible on regulated U.S. platforms. Please dont ban or over-restrict these valuable tools.
Sincerely,
Exequiel Punzalan
