Comment Text:
Dear Chairman and Commissioners,
My name is Jimi Rom, and I'm a student based in California. I'm writing to share my thoughts on the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. As someone who actively trades on platforms like Kalshi, I strongly support the idea of well-regulated prediction markets, and I hope the CFTC will craft rules that encourage innovation while keeping these markets safe and accessible.
I've found prediction markets to be incredibly valuable, not just for me personally, but for society as a whole. Trading on Kalshi has given me a way to engage with real-world events, from elections to economic indicators, in a way that feels meaningful. It's not gambling; it takes research and critical thinking to make informed trades. More importantly, the prices on these markets often provide insights that you can't get from polls or news pundits. I've seen firsthand how they can cut through noise and offer clearer signals about what might happen next. This kind of information isn't just useful for traders like me; it can help journalists, policymakers, and everyday people make better decisions. I think the CFTC should recognize this value when considering regulations, especially in response to Questions 7 and 8 from your ANPR about balancing innovation with consumer protection and the role of price discovery.
I also want to stress how important it is to keep these markets regulated and based in the US. Platforms like Kalshi operate under CFTC oversight, which means there are rules and accountability. If the CFTC over-restricts or bans certain types of event contracts, people aren't just going to stop trading. They'll turn to offshore platforms with no oversight, no consumer protections, and no recourse if something goes wrong. I've looked into some of those unregulated sites, and they feel like a Wild West compared to Kalshi. Pushing activity offshore doesn't solve problems; it makes them worse. On this point, I think Question 14 in your ANPR, about comparing prediction markets to other financial tools, is worth addressing. Regulated markets are a safer alternative, and the US has a chance to lead here.
That brings me to my last point. I believe the US should be at the forefront of financial innovation. As a student, I see how fast technology and markets are evolving. If we stifle prediction markets with heavy-handed rules, we're handing the future of this space to other countries. We should be setting the standard, not playing catch-up. I'd urge the CFTC to think about this when addressing Questions 33 to 40 on classification and cost-benefit considerations.
I understand there are concerns about manipulation or insider trading, but those issues are already illegal, and the CFTC has tools to enforce against bad actors. Don't punish everyone by limiting access to these markets. I respectfully ask that you support proportionate regulation of prediction markets, ensuring they remain legal, accessible, and based in the US under proper oversight.
Thank you for considering my perspective.
Sincerely,
Jimi Rom
