Comment Text:
Dear Chairman and Commissioners,
My name is Robert DiLeo, and I'm a trader and investor based in New York. I run a predictive sports betting business, and I also actively trade on prediction markets like Kalshi to bet the best lines I can find. I've been following the CFTC's Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516), and I want to share why I strongly support well-regulated prediction markets in the United States.
I've seen firsthand how prediction markets provide information you just can't get elsewhere. The prices on platforms like Kalshi often predict outcomes more accurately than polls or pundits on TV. As someone who analyzes data for a living, I rely on these markets to gauge probabilities on everything from elections to economic indicators. This isn't just useful for traders like me; it benefits anyone who needs reliable forecasts, including businesses and even policymakers.
What worries me is the alternative. If the CFTC over-restricts or bans these markets, activity won't disappear. Itll just move to unregulated offshore platforms where theres no oversight, no consumer protection, and no accountability. I've traded on Kalshi, which operates under CFTC rules as a designated contract market, and I feel much safer knowing there are guardrails in place. Regulation isn't the enemy here; lack of it is. Pushing traders like me to sketchy offshore sites would be a step backward.
I also believe the CFTC already has the tools to handle concerns like manipulation or insider trading. Your existing authority to combat market abuse in other derivatives markets can easily apply to event contracts. Banning or overly restricting prediction markets to stop a few bad actors feels like punishing everyone for something you can already address with current laws. And honestly, informed trading isn't a problem; its a strength. When knowledgeable participants trade, it sharpens the prices and makes the market's predictions more accurate, which helps everyone.
Id like to touch on a few specific questions from the ANPR. On Question 7, about balancing innovation and consumer protection, I think regulated markets like Kalshi strike the right balance by fostering innovation while keeping traders safe. On Question 29, regarding inside information, I believe informed traders improve price discovery, and existing laws already prohibit abuse by federal insiders.
Prediction markets aren't gambling. They take skill, research, and judgment, just like trading stocks or commodities. I urge the CFTC to support proportionate regulation that keeps these markets accessible and safe without driving activity offshore. Lets keep the U.S. as a leader in financial innovation.
Thank you for considering my input.
Sincerely,
Robert DiLeo
