Comment Text:
Dear Chairman and Commissioners,
My name is Phoenix Diacou, and I'm a student from Georgia writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I've been following this issue closely because I actively trade on platforms like Kalshi, and I believe well-regulated prediction markets offer real value to people like me and to society as a whole. I'm not a lawyer or a finance expert, just someone who sees these markets as a useful tool, and I want to make sure my perspective is heard before the April 30, 2026 deadline.
As a student, I spend a lot of time researching and analyzing information for my studies. Trading on prediction markets feels like an extension of that. It's not gambling, not by a long shot. When I place a trade on something like an election outcome or an economic indicator, I'm using judgment and data, much like I do when writing a paper or preparing for a debate. These markets give me access to information and insights I can't find in news articles or polls. The prices reflect what a lot of people, not just pundits, think will happen. That's valuable to me, and I think it's valuable to everyone when that kind of aggregated wisdom is out there for public use.
I also believe these event contracts serve real economic purposes. For someone like me, with student loans and a tight budget, being able to hedge against things like interest rate changes or inflation numbers affecting my costs is a practical benefit. It's not about betting for fun; it's about managing real-world risks. I worry that labeling these contracts as "gaming," as discussed in Questions 15-22 of the ANPR, misses the point of why people use them. They're more like investing than gambling, and I hope the CFTC sees that distinction.
On the concern about manipulation and insider trading, which comes up in Questions 29-32, I want to point out that the CFTC already has strong tools to handle these issues. Laws against insider trading apply to federal employees and others with nonpublic information, and your agency has broad authority to go after market manipulation in any regulated market. I've read about past cases where the CFTC stepped in to stop bad actors in other derivatives markets. I trust you can do the same here without needing to ban or over-restrict prediction markets. Shutting down something useful to stop a few cheaters feels like punishing the wrong people.
I appreciate the chance to weigh in on this. Prediction markets matter to me as a way to engage with the world and manage uncertainty. I urge the CFTC to support proportionate regulation that addresses specific risks without stifling innovation or access for regular people like me. Please keep these markets open and well-regulated.
Sincerely,
Phoenix Diacou
