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Comment for Proposed Rule 91 FR 12516

  • From: David Prina
    Organization(s):

    Comment No: 114665
    Date: 4/4/2026

    Comment Text:


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    Your voice needed
    David, In the past few years, so-called “prediction markets” like Kalshi and Polymarket have wormed their way into every aspect of the media, and increasingly, into our lives. These sites...


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    Your voice needed

    Faiz Shakir, More Perfect Union
    To
    [email protected]
    Apr 3

    Apr 3 at 3:56 PM
    More Perfect Union Logo
    David,

    In the past few years, so-called “prediction markets” like Kalshi and Polymarket have wormed their way into every aspect of the media, and increasingly, into our lives. These sites offer the ability to gamble on any topic you can think of -- from the number of minutes a White House briefing will last to whether or not we launch a war.

    The Commodity Futures Trading Commission is opening an official comment period on how the government should approach regulating these new financial instruments. They create real dangers for consumers who now essentially carry slot machines on their phones, and can be powerful conduits for insider trading among corrupt politicians.

    Some comment periods make it simple for us to submit official comments. We can build a form and have it submit directly into the government’s comment form, and your voices are heard. This one isn’t like that. But that can be a good thing. The same big money interests who are heavily invested in these prediction markets are aggressively adopting AI, and could stuff the comment form with machine-generated slop. From our reporting, we think there’s a big divide between what regular people want and the world that tech elites are building. And we need to make our voices heard.

    Here’s how you can stand up for common sense rules around prediction markets like Kalshi and Polymarket:

    First: Open this link in a new tab: https://comments.cftc.gov/PublicComments/CommentForm.aspx?id=7654

    Next: Scroll down and fill out the personalized information.

    Next:

    Enter your comment. We’ve got a sample comment that you can copy and paste, but we encourage you to edit it in order to personalize the message and differentiate it from the others.

    Sample comment:

    I am writing to urge the Commission to take strong regulatory action regarding event contract derivatives traded on prediction markets. The current trajectory of prediction markets raises serious concerns about market integrity, insider trading, and the commodification of events that should remain outside the realm of financial speculation. Event contracts that allow wagering on military operations, foreign policy decisions, terrorism, assassination, or other government actions create unacceptable risks because individuals with nonpublic information about those decisions have both the opportunity and financial incentive to exploit that information. When citizens perceive that government decisions may be influenced by private financial interests, it erodes public trust.

    I respectfully submit that the Commission should explicitly prohibit event contracts related to military operations, acts of war, terrorism, political assassinations, and non-financial government policy decisions as contrary to the public interest. Additionally, any event contract where the outcome can be known in advance or controlled by a specific individual or small group is inherently susceptible to manipulation and should face a presumption against approval. This includes award show results, political speeches, corporate announcements, and any event where insiders have definitive advance knowledge.

    The Commission has both the authority and responsibility under the Commodity Exchange Act to establish clear prohibitions on event contracts that are contrary to the public interest. I respectfully request that the Commission prohibit these dangerous categories of event contracts, strengthen surveillance and enforcement mechanisms to detect insider trading, and prioritize market integrity and public welfare over industry growth. The financialization of every aspect of human life, including war, death, and governance, should not proceed without meaningful guardrails, and the Commission's action on this rulemaking will signal whether our regulatory framework prioritizes public welfare or permits the commodification of matters that should remain beyond the reach of financial speculation.

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