Comment Text:
Dear Chairman and Commissioners,
My name is Ricardo Ayala, and I'm just an everyday citizen from Georgia. I'm 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 for a while now, and I strongly support well-regulated prediction markets. They're valuable to me and, I believe, to society as a whole.
I first got into prediction markets because I wanted better information to make sense of the world. Polls and pundits are often wrong, but the prices on these markets cut through the noise. They've consistently been more accurate about things like election outcomes or economic indicators. That kind of clarity isn't just helpful for traders like me; it's something everyone can benefit from, whether it's journalists, policymakers, or just regular folks trying to plan their lives. I also don't see this as gambling at all. Trading on Kalshi takes research and judgment, just like investing in stocks. These event contracts have real economic purposes, like price discovery, and labeling them as "gaming" feels like a misunderstanding.
One thing I'm worried about is the idea of over-restricting or banning these markets. Regulated platforms like Kalshi are safe and transparent, with oversight in place. If the CFTC clamps down too hard, people will just turn to unregulated offshore sites, which are far riskier. I've seen how well the current system can work, and I believe the CFTC already has strong tools to handle issues like manipulation or insider trading. There's no need to reinvent the wheel; just apply those existing safeguards to prediction markets.
I'm also a firm believer that informed trading makes these markets better. When people with good information trade, the prices get more accurate, and that helps everyone. Addressing some of the specific questions in the ANPR, like those in Topic B on public interest (Questions 7-9), I think the balance should tilt toward innovation. The U.S. has a chance to lead in this space, and we shouldn't cede that to other countries by over-regulating. And on Topic E, about inside information (Questions 29-31), I believe the benefits of informed trading for price discovery outweigh the risks, especially since insider trading laws already exist to deter bad actors.
I hope the CFTC will support proportionate regulation that allows prediction markets to thrive while addressing specific risks with targeted rules. Please don't ban or overly restrict these valuable tools. They're a net positive for people like me and for the broader public.
Sincerely,
Ricardo Ayala