Comment Text:
Dear Chairman and Commissioners,
My name is Ori Globus, and I'm a business owner from California. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I want to express my strong support for well-regulated prediction markets. They provide unique value to people like me, and I believe the CFTC should focus on proportionate regulation rather than restrictive bans or overreach.
Running a business means I'm constantly dealing with uncertainty, whether it's policy changes, economic shifts, or market trends. Prediction markets have been a game-changer for me. I've used platforms like Kalshi to get insights on things like interest rate decisions or election outcomes that could impact my taxes and operations. The prices on these markets often cut through the noise of pundits and polls, giving me a clearer picture of what might happen. Ive seen firsthand how these forecasts are more accurate than traditional sources, and thats not just useful for traders like me, its valuable for anyone trying to make informed decisions.
I also want to stress that event contracts arent gambling. When I trade on Kalshi, I'm not rolling dice. I'm researching, analyzing, and making judgments about real-world events, just like I do with other investments. These contracts serve a real economic purpose, whether its hedging risks or gaining information. Labeling them as "gaming," as discussed in Questions 15-22 of the ANPR, misses the point. Theyre tools for understanding and managing uncertainty, not games of chance.
Another concern I have is access. I value the freedom to participate in legal, regulated markets. If the CFTC clamps down too hard, people like me might turn to unregulated offshore platforms, which are far less safe. Regulated markets like Kalshi have oversight and protections in place. Pushing activity overseas, as could happen with overly restrictive rules, would hurt consumers and undermine the CFTCs mission. I urge you to consider this when addressing Questions 7-14 on balancing innovation and consumer protection.
I understand there are risks, like manipulation or insider trading. But the CFTC already has tools to tackle those issues. Punishing everyone by limiting access or banning certain contracts isnt the answer. Focus on enforcing existing laws and targeting bad actors instead. Id encourage you to look at Questions 29-32 on inside information and ensure that regulations address specific risks without shutting down the broader benefits of these markets.
In closing, I ask the CFTC to support proportionate regulation of prediction markets. Theyre a powerful tool for people like me, providing unique information and economic utility. Please dont over-restrict or ban them. Instead, build a framework that keeps them safe and accessible for everyday Americans.
Sincerely,
Ori Globus
