Comment Text:
Dear Chairman and Commissioners,
My name is Kabir Singh, and I'm a software engineer from Connecticut. I work in the tech industry, specifically developing software for prediction markets like Kalshi. I also actively trade on these platforms, so I have a personal and professional stake in how they are regulated. I'm writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets (91 FR 12516) to urge the CFTC to support proportionate regulation of these markets rather than imposing bans or overly restrictive rules.
As someone building software for prediction markets, I see firsthand how they aggregate information in ways that polls or pundits often can't match. Academic research backs this up, studies by economists like Hanson and Wolfers show that these markets produce more accurate forecasts by pooling diverse perspectives. I trade on Kalshi myself, and I've used it to hedge personal financial risks, like potential tax changes tied to election outcomes. This isn't gambling, it's a legitimate economic tool. I research data, analyze trends, and make informed decisions, just like I would with stocks or other investments. Classifying event contracts as "gaming" (as raised in Questions 15-22) ignores their real purpose in price discovery and risk management.
I'm also concerned about the idea of banning or over-restricting these markets. If the CFTC makes it too hard to operate legally in the US, activity will just move offshore to unregulated platforms. I've seen this in tech, people find workarounds when access is blocked. Regulated markets like Kalshi are safer, with transparency and oversight. Pushing traders to sketchy offshore sites helps no one. I hope the CFTC considers this when addressing public interest concerns in Questions 7-14.
Another point I want to stress is the value of informed trading. As a developer, I know data transparency makes markets better. When knowledgeable traders participate, prices reflect reality more accurately, which benefits everyone, not just those trading. The CFTC's Questions 29-32 ask about insider trading risks, and I get the concern. But existing laws already prohibit federal employees or others from abusing nonpublic info. Enforce those rules instead of punishing all participants by limiting markets.
Prediction markets aren't just a niche interest for me, they're a tool for understanding the world and managing uncertainty. I've seen their value in my trades and in the software I build. I ask the CFTC to regulate these markets with a light touch, focusing on specific risks like manipulation without broad bans. Lets keep innovation and access alive in the US.
Thank you for considering my perspective.
Sincerely,
Kabir Singh
