Comment Text:
Dear Chairman and Commissioners,
My name is Johvany Benjamin, and I'm a trader and investor based in Florida. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing to support well-regulated prediction markets in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I believe these markets provide real value to people like me and to society as a whole, and I hope the CFTC will regulate them in a way that fosters innovation without over-restricting access.
As a trader, I rely on prediction markets for accurate forecasting of elections and other public events. The prices on these platforms often cut through the noise of polls and pundits, giving me a clearer picture of whats likely to happen. This isnt just useful for trading; it helps me make informed decisions in other areas of my life and business. Beyond forecasting, I use these markets to hedge personal financial risks. For instance, trading on election outcomes or economic indicators helps me offset uncertainties that could impact my investments or taxes. This isnt gambling. Its a legitimate tool for managing real-world risks, much like trading futures or options in other markets.
I also want to stress that regulated platforms like Kalshi are far safer than unregulated offshore alternatives. Ive seen what happens when access to legitimate markets is restricted. People dont stop trading; they just move to sketchy offshore sites with no oversight, no consumer protections, and no accountability. If the CFTC over-restricts or bans certain event contracts, thats exactly where activity will go. Keeping these markets regulated here in the US ensures transparency and safety for traders like me. Plus, the US should be leading the way in financial innovation. We shouldnt cede this space to other countries by making it too hard to operate here.
I noticed some of the CFTCs questions in the ANPR, particularly around public interest (Questions 7-14) and listed activities (Questions 15-22). On public interest, I believe prediction markets serve a clear benefit through price discovery and risk management, and that benefit outweighs the risks if proper safeguards are in place. On listed activities, I urge the CFTC not to classify event contracts as gaming. They serve economic purposes like hedging and forecasting, which are distinct from gambling. As for concerns about manipulation or insider trading, I get why those are issues. But the CFTC already has tools to address fraud and manipulation in other markets. Use those tools here instead of broad bans that punish everyone.
Im asking the CFTC to support proportionate regulation of prediction markets. Dont over-restrict or ban them. Keep them accessible, safe, and regulated here in the US so traders like me can continue to benefit from their unique value. Thank you for considering my input.
Sincerely,
Johvany Benjamin
