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Comment for Proposed Rule 91 FR 12516

  • From: Richard Mullininx
    Organization(s):

    Comment No: 116595
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Richard Mullininx, and I'm a software engineer from Georgia. I work in tech, and I'm fascinated by cutting-edge technologies and human behavior. That's why I'm drawn to prediction markets like Kalshi, which combine both in a unique way. I've been actively trading on Kalshi, and Im excited to see how it evolves. I'm writing to express my strong support for well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets offer real value to society and to people like me, and I urge the CFTC to adopt proportionate regulations rather than overly restrictive bans.


    As someone who geeks out on data and systems, I find Kalshi's ability to predict real-world events incredibly impressive. Time and again, prediction markets have outperformed polls and pundits when it comes to forecasting elections and other public events. That kind of accuracy isn't just neat to watch; its useful for everyone, from regular folks like me to policymakers and businesses who need better information for decision-making. These markets also help with price discovery, aggregating insights in a way nothing else does. I think informed trading actually improves those outcomes, benefiting all participants, which ties directly to your questions 7 and 29 on public interest and inside information.


    Beyond forecasting, I've used Kalshi to hedge personal financial risks tied to economic or political outcomes. For instance, knowing an election result might impact tech regulations or taxes helps me plan better. This isn't gambling; its a legitimate tool for managing uncertainty, much like any other investment. I strongly believe event contracts shouldn't be classified as "gaming" since they serve real economic purposes, a point I hope youll consider under questions 15 and 16 on listed activities.


    I'm also concerned about freedom and fairness. Banning or over-restricting these markets would push activity to unregulated offshore platforms, which are far less safe for consumers. I'd much rather see the CFTC regulate platforms like Kalshi to protect users while keeping the U.S. competitive in financial innovation. We should be leading on this, not ceding ground to other countries. This relates to your questions 7 and 8 on balancing innovation and consumer protection. Targeted rules addressing specific risks like manipulation or insider trading make more sense than broad categorical bans. You already have tools to tackle bad actors; use those instead of punishing everyone.


    Im passionate about seeing Kalshi and similar platforms studied and regulated thoughtfully, not shut down. Theyre a glimpse into how technology can solve real problems. Please support proportionate regulation that allows prediction markets to thrive while addressing legitimate concerns with precision.


    Thank you for considering my input.


    Sincerely,

    Richard Mullininx

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