Comment Text:
Dear Chairman and Commissioners,
My name is Talkulu Kulah, and I'm a student at Concordia University in Minnesota. I'm 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). As someone who actively trades on platforms like Kalshi, I see firsthand the value these markets bring, not just to me but to society as a whole, and I believe the CFTC should regulate them proportionately rather than impose overly restrictive rules or bans.
Prediction markets aren't just a hobby for me; they're a tool to understand real-world events and manage risks. As a student, I'm often looking at live trades on Kalshi to see how election outcomes or economic indicators might affect my future job prospects or even my family's small business back home. These markets let me hedge against uncertainties, like policy changes that could impact tuition costs or local taxes. This isn't gambling. It takes research and judgment, just like investing in stocks. I believe event contracts serve real economic purposes, as highlighted in Questions 15-22 of your ANPR, and shouldn't be lumped in with gaming.
I also care deeply about academic research and data transparency. Prediction markets provide unique, aggregated information that often outpaces polls or pundits. I've read studies showing how these markets improve forecasting, and as a student, I think this data should be accessible for research. It benefits everyone when prices reflect the most accurate information, which ties into Questions 29-32 about informed trading. I believe informed traders actually help price discovery, making markets more accurate for all participants, not just a few insiders.
I'm not blind to the risks of manipulation or insider trading, but I trust the CFTC already has strong tools to tackle these issues. You've got authority to go after bad actors in any regulated market, and that should apply here too. Banning or over-restricting prediction markets, as discussed in Questions 7-14 on public interest, would just push activity to unregulated offshore platforms. That's worse for consumer protection. Instead, targeted rules addressing specific risks make more sense than broad categorical bans.
Lastly, I think the US should be a leader in financial innovation. If we stifle prediction markets, other countries will step in, and we'll lose the chance to set the standard. I'm just a student, but I value my freedom to participate in legal, regulated markets like these. They give regular people like me a stake in understanding the world, and that shouldn't be taken away.
I urge the CFTC to support proportionate regulation of prediction markets, focusing on specific risks rather than sweeping restrictions. Thank you for considering my perspective.
Sincerely,
Talkulu Kulah
