Comment Text:
Dear Chairman and Commissioners,
My name is Ayan Sivaram, and I'm a student and academic based in New York. I'm writing to express my strong support for the proportionate regulation of prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). As someone who actively trades on platforms like Kalshi and Polymarket, I've seen firsthand the value these markets provide, not just to me but to society at large. I believe the CFTC has an opportunity to foster innovation while protecting consumers through thoughtful rules, and I want to share my perspective.
Prediction markets aren't just a hobby for me; they're a tool for understanding the world. I've used them to follow elections and other public events, and I'm consistently impressed by how their forecasts beat out polls or pundits. As a student, I rely on accurate information to make sense of complex issues, and these markets provide insights I can't get elsewhere. They're not gambling, either. Trading on them requires research and judgment, much like investing in stocks. Classifying event contracts as "gaming" (as discussed in Questions 15-22) ignores their real economic purpose, whether it's price discovery or helping people hedge risks. For example, I've used these markets to hedge personal financial decisions tied to economic data releases, like inflation numbers that affect my budget.
I also worry about what happens if regulation becomes too restrictive. Regulated platforms like Kalshi, operating under CFTC oversight, are safe and transparent. If access is limited, people like me will turn to unregulated offshore platforms, which are far riskier. I'd rather see the CFTC focus on keeping markets fair and accessible here in the U.S. (as raised in Questions 7-14 on public interest). Additionally, as an academic, I value the data these markets generate. They're a goldmine for research on human behavior and forecasting, and transparent, regulated markets ensure that data is reliable.
On the topic of informed trading (Questions 29-32), I believe it actually helps price discovery. When knowledgeable traders participate, prices get more accurate, which benefits everyone, not just those trading. The CFTC already has tools to tackle insider trading and manipulation. Banning or over-restricting markets to stop a few bad actors punishes the rest of us who use them responsibly.
I'm asking the CFTC to support well-regulated prediction markets that allow everyday people like me to participate. Don't ban broad categories of event contracts or impose rules that push activity offshore. Instead, craft targeted regulations that address specific risks while preserving the forecasting, hedging, and informational benefits these markets offer. Thank you for considering my input.
Sincerely,
Ayan Sivaram
