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Comment for Proposed Rule 91 FR 12516

  • From: Shri Sukhani
    Organization(s):

    Comment No: 116997
    Date: 4/30/2026

    Comment Text:

    Dear Chairman and Commissioners,


    My name is Shri Sukhani, and I'm a software engineer based in California. I work in tech, where data and innovation drive everything we do, and that's why I'm writing to comment on the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516). I'm new to prediction markets, but I strongly support their development under fair, proportionate regulation by the CFTC.


    As someone who values accurate information, I see prediction markets as a powerful tool. They've consistently outperformed polls and pundits in forecasting elections and other public events. That kind of insight isn't just useful for traders; it helps everyone, from regular citizens to policymakers, make better decisions. I also believe these markets let people like me hedge real financial risks. For instance, if an election outcome could impact tech regulations or taxes that affect my income or my company's bottom line, trading on a prediction market could help me offset that uncertainty. This isn't gambling. It's a thoughtful process, much like investing in stocks, requiring research and judgment about real-world events.


    I'm also concerned about access and fairness. Prediction markets give ordinary people a chance to participate, and that's a good thing. If we over-restrict or ban them, as some might suggest, it pushes activity to unregulated offshore platforms where there's no oversight. I'd much rather see markets like Kalshi, which operate under CFTC rules, thrive here in the U.S. Regulated markets are safer for consumers and keep the U.S. competitive in financial innovation. We shouldn't cede this space to other countries; we should lead it. On top of that, academic research backs these markets as a way to aggregate information efficiently. Informed trading, even if it looks like an advantage, actually improves price discovery for everyone.


    I want to address some of the CFTC's specific questions. Regarding Public Interest (Questions 7-14), I think the balance tips toward innovation when regulation is done right. Prediction markets aren't just games; they serve legitimate economic purposes like hedging and forecasting. On Inside Information (Questions 29-32), I believe the CFTC's existing tools to combat manipulation and insider trading are enough. Banning entire categories of contracts to stop a few bad actors punishes the rest of us. Targeted rules make more sense than broad restrictions.


    I urge the CFTC to support prediction markets with clear, balanced regulations that protect consumers without stifling innovation. Let's keep these markets legal, accessible, and safe right here in the U.S. Thank you for considering my input.


    Sincerely,

    Shri Sukhani

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