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Comment for Proposed Rule 91 FR 12516

  • From: Jeremy F
    Organization(s):
    Trader

    Comment No: 115371
    Date: 4/30/2026

    Comment Text:

    To whom it may concern,

    I am very familiar with trading stocks, playing casino games, betting on sports, and now trading on prediction markets.

    While I fully understand jumping to worry about the newest addition to the market, I find the pearl clutching to be hypocritical when the other three are actively encouraged.

    When trading stocks, I found myself being late to breaking news that was somehow already "priced in" or being directionally correct on earnings only to see my stocks go down anyway. Citadel somehow didn't have that problem.

    When family members went bust at the casino, they weren't met with a concerned staff member making sure they stayed within their means. They had VIP hosts sending a car to their house monthly to pick them up on the day their government assistance check came (true story!)

    When I used my sports knowledge to more accurately gauge who would win basketball games than the sportsbooks, almost all of them quickly banned me from betting or limited me to betting $1 at a time. Meanwhile, my gambling addict friends got their limits raised and got sent special gifts. Every time I see the commercials during every sporting event advertising "winning big" I laugh that you'll be shown the door before you have a chance to.

    Prediction markets, like the other three, are a zero-sum game so there will be winners and losers. I don't claim to believe Kalshi is altruistic in their endeavors, but I do find peer-to-peer wagering on a transparent marketplace to be less predatory than any of the other mediums that we've celebrated for decades.

    That said, I understand the need for guardrails. So far, their efforts to punish insider trading are a step in the right direction, but need to continue to be more robust. Certain markets that incentivize societal harm should be eliminated. But don't throw the baby out with the bathwater here and eliminate an entire structure due to problems with a product in its absolute infancy.

    Thank you for your time.

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