Comment Text:
Dear Chairman and Commissioners,
My name is William Quesada, and I'm a student from California writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been actively trading on platforms like Kalshi and Polymarket for a while now, and I believe well-regulated prediction markets are valuable for people like me and for society as a whole. I want to urge the CFTC to support proportionate regulation rather than imposing overly restrictive rules or outright bans.
As a student, I find prediction markets fascinating because they provide information that's hard to get anywhere else. Whether it's an election outcome or an economic indicator like a CPI print, the prices on these platforms often cut through the noise of pundits and polls. I've used this data to better understand public events and even to make small trades that hedge against outcomes that could affect my future, like policy changes impacting student loans or tuition costs. This isn't gambling to me. It takes research and judgment, just like any other investment. Classifying event contracts as "gaming," as discussed in Questions 15-22, overlooks their legitimate economic purpose, like price discovery and risk management, which I believe benefits everyone.
I'm also concerned about consumer protection, which ties into Questions 7-14 on public interest. I trade on Kalshi because it's regulated by the CFTC, and that gives me confidence my funds are safer than they would be on offshore platforms. If the CFTC over-restricts or bans these markets, people like me will get pushed to unregulated sites with no oversight. That's a worse outcome for everyone. The US should be leading in financial innovation, not ceding ground to other countries where these markets might thrive without proper rules.
I know there are valid concerns about manipulation and insider trading, as raised in Questions 29-32. But the CFTC already has strong tools to tackle those issues in other derivatives markets. I trust those can be adapted here without punishing the majority of honest traders with broad categorical bans. Targeted regulation makes more sense to me than shutting down an entire space because of a few bad actors.
Prediction markets give regular people like me a chance to participate in legal, regulated spaces that improve public decision-making through better information. I hope the CFTC will craft rules that protect consumers while allowing this innovation to grow. Please focus on proportionate regulation that keeps markets safe and accessible without driving activity offshore.
Thank you for considering my input.
Sincerely,
William Quesada
