Comment Text:
Dear Chairman and Commissioners,
My name is Samuel Urjilez, and I'm a student from New Jersey. Im writing in response to the Advance Notice of Proposed Rulemaking on Prediction Markets, as published in 91 FR 12516. Ive been actively trading on platforms like Kalshi for a while now, and Im passionate about the value these markets bring to people like me, as well as to society at large. I want to urge the CFTC to support proportionate regulation of prediction markets rather than imposing overly restrictive rules or outright bans.
As a student, I find prediction markets fascinating because they often provide more accurate forecasts for elections and other public events than polls or pundits. Ive seen this firsthand while following political races and economic indicators. These markets aggregate information in a way thats just not available elsewhere, and that benefits not only traders but also anyone who relies on good data for decision-making. Beyond that, I value the freedom to participate in legal, regulated markets. Its empowering to have a stake in understanding real-world events, and I believe this kind of democratized access improves price discovery for everyone.
I also think the U.S. should be a leader in financial innovation. If we over-restrict prediction markets, we risk pushing activity to unregulated offshore platforms, which are far less safe for consumers. Regulated markets like Kalshi offer protections that offshore alternatives dont, and Id rather see the CFTC focus on strengthening those protections than driving innovation abroad. On a related note, Ive read academic research showing how informed trading actually improves market accuracy. Banning or limiting these markets to stop a few bad actors would hurt the rest of us who use them responsibly. Plus, the CFTC already has strong tools to address manipulation and insider trading in other derivatives. Why not adapt those for event contracts instead of broad categorical restrictions?
I want to address a specific concern Ive seen raised, which ties to Questions 15-22 in the ANPR about defining gaming versus legitimate markets. I strongly believe event contracts arent gambling. They serve real economic purposes, like hedging risks. For example, Ive used prediction markets to offset personal financial uncertainties tied to policy changes. Thats no different from how businesses or individuals hedge in other markets. Calling this gaming feels like a misstep.
Im also drawn to the transparency and data these markets provide, which ties to Questions 7-14 on public interest. The insights from prediction markets can inform public decision-making in ways that benefit everyone, not just traders. So I ask the CFTC to regulate proportionately. Target specific risks like manipulation with focused rules, but dont ban or overly restrict these valuable tools.
Thank you for considering my perspective. I hope youll support a regulatory framework that allows prediction markets to thrive safely in the U.S.
Sincerely,
Samuel Urjilez
