Comment Text:
Dear Chairman and Commissioners,
My name is Rakes Dong, and I'm a trader and investor based in Colorado. I've been actively trading on prediction markets like Kalshi for a while now, and I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the idea of well-regulated prediction markets and want to share why I believe the CFTC should focus on proportionate regulation rather than restrictive bans or overreach.
As someone who trades regularly, I value the freedom to participate in legal, regulated markets. Prediction markets aren't just a hobby for me; they're a way to engage with real-world events and make informed decisions based on research and judgment. I've used platforms like Kalshi to trade on outcomes like election results or economic data releases, and the information these markets provide often feels more reliable than what I see in polls or news commentary. This isn't gambling. It takes skill and attention, much like trading stocks or commodities. I think allowing regular folks like me to participate makes these markets more accurate and democratizes access to valuable insights.
One of my biggest concerns is the alternative to regulated markets. I've seen unregulated offshore platforms out there, and they're far riskier. No oversight, no consumer protections, just a black box. If the CFTC over-restricts or bans prediction markets in the U.S., people won't stop trading; they'll just move to those shady venues. I know I feel safer on a platform like Kalshi, which operates under CFTC rules. Regulation keeps things transparent and holds platforms accountable. I'd hate to see that safety net taken away. This ties directly to questions 7 and 8 in your ANPR about balancing innovation with consumer protection. I believe regulated markets strike that balance by keeping activity onshore where the CFTC can watch over it.
I also want to address a concern I know comes up, like in questions 29 to 32 about insider trading. I get why that's a worry, but shutting down markets isn't the answer. Insider trading and manipulation are already illegal, and the CFTC has tools to enforce those laws. Punishing everyone by restricting access because of a few bad actors feels unfair. Focus on catching the cheaters, not banning the game.
I'm asking the CFTC to support prediction markets with fair, targeted rules that address specific risks without stifling participation. Keep platforms like Kalshi operating under clear guidelines so traders like me can continue using them safely. Let's not push this activity offshore where no one benefits.
Thank you for considering my input.
Sincerely,
Rakes Dong