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Comment for Proposed Rule 91 FR 12516

  • From: Nicholas Gil
    Organization(s):

    Comment No: 116951
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Nicholas Gil, and I'm a trader and investor based in Texas. I've been actively trading on prediction markets like Kalshi for a while now, and Im writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I strongly support the idea of well-regulated prediction markets, and I hope my perspective as someone who uses these platforms can help shape a balanced approach.


    I rely on prediction markets to hedge real risks in my life and portfolio. For example, Ive traded contracts tied to election outcomes because political changes directly impact my taxes and investment strategies. Ive also used markets tied to economic data releases, like CPI numbers, to offset risks tied to inflation affecting my costs. This isnt gambling to me. Its a practical tool, much like trading futures or options to manage uncertainty. Classifying event contracts as gaming feels wrong when they serve legitimate economic purposes like price discovery and risk management. Id urge you to consider this in your responses to Questions 15-22 about defining gaming versus legitimate markets.


    I also value the freedom to participate in legal, regulated platforms like Kalshi, which operates under CFTC oversight. That regulation gives me confidence that there are safeguards against manipulation and fraud. Banning or over-restricting these markets would likely push activity to unregulated offshore platforms, which are far riskier for consumers like me. Regulation, not prohibition, is the way to protect participants. This ties to Questions 7-14 on balancing innovation with consumer protection, and I believe regulated markets are the safer path.


    Another point I want to stress is the value of informed trading. When people with knowledge trade, it makes the prices more accurate, which benefits everyone, not just traders. Shutting down markets over fears of insider trading punishes honest participants like me. The CFTC already has tools to tackle manipulation and insider trading, as noted in Questions 29-32. Use those tools, dont ban the market. And lets not forget, the U.S. should be leading in financial innovation. If we over-regulate, other countries will take the lead, and well lose out.


    Im asking you to support proportionate regulation that targets specific risks without broad bans. Focus on enforcement of existing laws against manipulation and insider trading, and keep platforms like Kalshi accessible to everyday traders. Prediction markets are a powerful tool for hedging and understanding the world. Lets not throw that away.


    Thank you for considering my input.


    Sincerely,

    Nicholas Gil

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