Comment Text:
Dear Chairman and Commissioners,
My name is Rafael Gonzalez, and I'm a regular citizen from California writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. I'm not an expert or a big-time trader, just someone who believes these markets have a lot of value and shouldn't be shut down or over-regulated. I'm pretty new to prediction markets, but I've been following the discussion and wanted to weigh in because I think they deserve a fair shot.
I strongly support the idea of regulated prediction markets. From what I've seen, platforms like Kalshi, which operate under CFTC oversight, are a much safer and more transparent option compared to unregulated offshore sites. If we ban or put too many restrictions on these markets here in the US, people aren't just going to stop trading. They'll go to those offshore platforms where there's no oversight, no consumer protection, and no accountability. That seems like a step backward to me. I'd much rather see the CFTC focus on making sure legal, regulated markets work well for everyday people like me.
Another thing that bothers me is the idea of classifying event contracts as gambling or "gaming." I don't see it that way at all. When I look at prediction markets, I see a tool for understanding the world better, not a slot machine. These contracts let people put money on real-world outcomes, like elections or economic data, based on research and judgment. That's not luck, it's analysis. It serves a real purpose, whether it's helping someone hedge a risk or just getting a clearer picture of what might happen. I think the CFTC should recognize that economic value and not lump these contracts in with casino games.
I'm also aware of concerns about manipulation or insider trading, and I get why that's a worry. But from what I understand, the CFTC already has strong tools to tackle those issues in other markets. Can't those same rules apply here? Punishing everyone by banning or over-restricting prediction markets because of a few bad actors doesn't seem right. I believe in the freedom to participate in legal, regulated markets, and I trust the CFTC can handle the risks without throwing the baby out with the bathwater.
Looking at some of the specific questions in the ANPR, I want to address Question 15 about defining gaming versus legitimate markets. Again, I think event contracts are legitimate tools for price discovery and risk management, not gambling. And on Question 7, about balancing innovation and consumer protection, I think supporting regulated markets like Kalshi strikes that balance by encouraging new ideas while keeping traders safe.
I urge the CFTC to support proportionate regulation of prediction markets. Please don't ban or over-restrict them. Let's keep these markets legal, safe, and accessible to regular folks like me. Thank you for considering my perspective.
Sincerely,
Rafael Gonzalez