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Comment for Proposed Rule 91 FR 12516

  • From: Jarom Severson
    Organization(s):
    Kalshi

    Comment No: 115387
    Date: 4/30/2026

    Comment Text:

    To the CFTC,

    I just wanted to share my thoughts on prediction markets and platforms like Kalshi.

    One thing that stands out to me is Kalshi doesnt operate like a typical gaming platform. They dont limit or ban winning traders and actually seem to encourage people who are profitable. That feels like the opposite of what you would expect if this was designed like gambling.

    Theres also a lot of transparency. You can see the full order book, watch prices move in real time, and place limit orders just like other financial markets. Thats not really something you see in anything that would be considered gaming.

    Another big thing is hedging. People are using Kalshi to offset real world risks, whether its business related or tied to economic outcomes or events. That seems like a pretty normal and useful function of a market.

    Also trading on these platforms actually takes research and judgment. People are reading info, forming opinions about real world outcomes, and making decisions based on that. Thats not that different from trading stocks or commodities. Calling it gaming would kind of imply that all investing is gaming which doesnt really make sense.

    Kalshi also has strict rules against insider trading. Like any market there can be bad actors, but it doesnt seem right to judge the whole thing based on a few cases. We wouldnt do that with other regulated exchanges.

    Overall I see prediction markets as a legit financial tool that should be regulated thoughtfully, not just labeled as gaming.

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