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Comment for Proposed Rule 91 FR 12516

  • From: Anthony Ayvaz
    Organization(s):

    Comment No: 117389
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Anthony Ayvaz, and I'm a trader and investor based in Maryland. I've been actively trading on prediction markets like Kalshi and Polymarket for a while now, and Im writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide unique value to individuals like me, as well as to society at large, and I urge the CFTC to adopt proportionate regulations rather than broad restrictions or bans.


    As a trader, Ive seen firsthand how prediction markets offer insights you cant get from polls or pundits. Their forecasts on elections and other public events have consistently been more accurate, which helps me make informed decisions both in trading and in my broader financial planning. Beyond that, these markets let me hedge real risks. For example, Ive used event contracts to offset potential impacts of policy changes or economic data releases that could affect my investments. This isnt gambling. Its a calculated process involving research and judgment, much like trading stocks or commodities. Classifying event contracts as gaming feels misguided to me when they serve such clear economic purposes.


    Im also concerned about the alternative if the CFTC over-restricts these markets. Regulated platforms like Kalshi, operating under CFTC oversight, are far safer than unregulated offshore sites. If access is limited here, activity will just shift to less transparent venues, putting traders like me at greater risk. The U.S. should be leading in financial innovation, not ceding ground to other countries. We have a chance to set a global standard with smart regulation, and I hope the CFTC takes it.


    Addressing some of your specific questions, I believe informed trading enhances price discovery and benefits everyone, as raised in Questions 29-32 on inside information. Banning markets to stop a few bad actors isnt the answer; it punishes honest participants. The CFTC already has strong tools to combat manipulation and insider trading in other derivatives markets. Those can be adapted here without resorting to categorical bans. On Questions 15-22 about listed activities, I urge you to recognize that event contracts arent gaming but legitimate tools for hedging and forecasting. And in response to Questions 7-14 on public interest, Id argue that balancing innovation with consumer protection means targeted rules, not broad prohibitions.


    I understand there are concerns about manipulation or misuse, and those shouldnt be ignored. But the solution is using existing enforcement powers and crafting specific safeguards, not shutting down an entire market that provides real value. Prediction markets democratize access to information and incentivize civic engagement. Plus, academic research backs their role in aggregating data efficiently. Lets keep this tool available under fair oversight.


    I respectfully ask the CFTC to support proportionate regulation of prediction markets and avoid over-restrictive measures that could harm traders and innovation in the U.S.


    Sincerely,

    Anthony Ayvaz

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