Comment Text:
Dear Chairman and Commissioners,
My name is Jesus Gutierrez, and I'm a software engineer from New Mexico. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I actively trade on platforms like Kalshi, and I believe that well-regulated prediction markets offer real value to people like me and to society as a whole. I want to urge the CFTC to support proportionate regulation of these markets rather than imposing overly restrictive rules or bans.
As someone in tech, I value data and accuracy. Prediction markets stand out because they consistently produce forecasts that beat polls or pundits. I've seen this firsthand on Kalshi, where the aggregated wisdom of traders often cuts through the noise of media speculation. Whether it's an election outcome or an economic indicator, these prices give me insights I can't find anywhere else. This isn't just useful for traders; it benefits anyone who wants a clearer picture of the future, from policymakers to regular citizens.
I also want to push back on the idea that event contracts are gambling. They aren't. Trading on prediction markets requires research, analysis, and judgment about real-world events, much like trading stocks or commodities. For me, it's a way to hedge against uncertainties that affect my life, like policy changes that could impact tech regulations or funding for projects I'm involved in. These contracts serve a legitimate economic purpose, and labeling them as "gaming" misunderstands their function. I think the CFTC should focus on this distinction when addressing questions like 15 and 16 from the ANPR about defining gaming versus legitimate markets.
Another big concern for me is safety. I trade on Kalshi because it's regulated by the CFTC, which gives me confidence that there are rules in place to prevent manipulation or fraud. If the CFTC over-restricts or bans these markets, people like me won't stop trading; we'll just get pushed to unregulated offshore platforms where there are no protections. That's a worse outcome for everyone. On questions 7 and 8 about balancing innovation and consumer protection, I strongly believe that regulated markets are the answer, not prohibitions.
I'm not blind to the risks. Insider trading or manipulation could be issues, but the CFTC already has tools to address those in other markets. Use those same tools here instead of punishing all traders with broad restrictions. Prediction markets are too valuable to stifle. They democratize access to information and let regular people like me participate in a system that would otherwise be dominated by big institutions.
I respectfully ask the CFTC to craft rules that support innovation while addressing specific risks with targeted measures. Please don't let overregulation drive this useful tool underground. Thank you for considering my perspective.
Sincerely,
Jesus Gutierrez
