Comment Text:
Dear Chairman and Commissioners,
My name is Lukas Walla, and I'm an independent trader and data analyst from California. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I actively trade on platforms like Kalshi, and I rely on these markets every day as a legitimate tool for risk management and forecasting. I strongly support well-regulated prediction markets and urge the CFTC to adopt proportionate rules that protect consumers without stifling innovation or pushing activity offshore.
For me, prediction markets have replaced unreliable polls and pundit speculation. They provide a real, crowd-sourced signal that moves with facts on the ground. When thousands of people put money behind their predictions, they research, think hard, and update fast. That's not gambling; it's how efficient markets work. I've seen these platforms mature into serious financial instruments that serve real economic purposes, like hedging risks tied to elections, economic data releases, or policy changes that impact my finances. This isn't a hobby. It's a sophisticated, legal activity I depend on for better decision-making.
I'm concerned that over-restricting these markets would be a step backward for American financial innovation. Addressing Questions 7 and 8 under Public Interest, I believe prediction markets benefit society by producing more accurate forecasts than traditional methods. They also democratize access to information, letting regular people like me participate alongside institutions. On Question 15 under Listed Activities, I urge the CFTC not to classify event contracts as gaming. They aren't about luck; they require judgment and analysis, much like trading stocks or commodities. Hedging real risks, whether personal or business-related, is a legitimate use.
I also want to highlight the danger of driving activity offshore, relevant to Questions 7 and 33 on public interest and regulatory costs. If the CFTC bans or over-restricts these markets, Americans won't stop trading; we'll turn to unregulated foreign platforms with no oversight or consumer protections. Regulated U.S. markets like Kalshi operate under strict anti-fraud and anti-manipulation rules. They're the solution, not the problem. The CFTC already has robust tools to address insider trading and manipulation, as raised in Questions 29 and 30. Informed trading actually improves price discovery, benefiting everyone. The answer isn't broad bans but targeted enforcement of existing laws.
The U.S. should lead in financial innovation, not cede ground to other countries. Proportionate regulation, not categorical restrictions, is the way forward. I ask the CFTC to support regulated prediction markets, ensuring Americans like me can access safe, transparent domestic platforms while maintaining strong oversight to protect the public.
Thank you for considering my input.
Sincerely,
Lukas Walla
