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Comment for Proposed Rule 91 FR 12516

  • From: Adam Garfield
    Organization(s):

    Comment No: 117375
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Adam Garfield, and I'm a journalist and content creator based in Texas. I've worked in media for years, often focusing on public events and political trends, and I've collaborated with Kalshi on multiple projects. Their platform has become incredibly important to me, both professionally and personally, as I actively trade on prediction markets like theirs. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to urge the CFTC to support proportionate regulation of these markets, not bans or overly restrictive rules.


    As someone who analyzes and reports on public events, I can tell you that prediction markets provide information you just can't find elsewhere. Their forecasts on elections and other major events are often more accurate than traditional polls or pundit opinions. This isn't just helpful for traders like me; its valuable for the public, media, and even policymakers who need reliable data for decision-making. Ive used Kalshi to gain insights into election outcomes, which directly informs my content and helps my audience understand whats at stake. Beyond that, these markets let regular folks like me hedge real risks. Whether its an election result that could impact my taxes or a policy shift affecting my work, trading on Kalshi gives me a way to manage uncertainty.


    I also want to be clear that event contracts are not gambling. They serve real economic purposes like price discovery and risk management. Calling them "gaming" ignores the research and judgment involved, much like investing in stocks or commodities. Im worried, though, about the idea of banning or over-restricting these markets. If that happens, activity will just move to unregulated offshore platforms, which are far less safe. Kalshi, as a regulated market under CFTC oversight, offers protections that offshore sites dont. Pushing trading overseas would hurt American innovation and the economy. Kalshi is a key part of the American dream, creating opportunities for regular people while keeping activity here at home.


    On specific points in the ANPR, Id like to address Questions 7 and 8 under Public Interest. Prediction markets balance innovation with consumer protection when regulated properly, as Kalshi is. The CFTC already has strong tools to tackle manipulation and insider trading, as noted in Questions 29-32 on Inside Information. Theres no need for broad bans; just enforce the rules youve got. And on Question 15 under Listed Activities, event contracts shouldnt be lumped in with gaming. Theyre a legitimate financial tool.


    I urge the CFTC to regulate prediction markets in a way that protects participants without stifling innovation. The U.S. should lead in this space, not cede ground to other countries. Lets keep platforms like Kalshi thriving under fair rules.


    Sincerely,

    Adam Garfield

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