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Comment for Proposed Rule 89 FR 48968

  • From: Adhitya Rajaprabhakaran
    Organization(s):
    Kalshi Trading

    Comment No: 73780
    Date: 6/14/2024

    Comment Text:

    Dear CFTC Recipient,

    I am writing to you as a professional prediction market trader whose living depends on the regulated marketplace. I want to express my views on the importance of Election contracts, Awards shows and contests, and Sports contracts in the regulated marketplace.

    The significance of prediction markets cannot be overstated. As someone whose livelihood is intricately tied to these markets, I can attest to their value. Event contracts, particularly those related to elections, are legal, regulated, and safe. They offer a structured environment for managing risks and provide invaluable information to the public and various sectors.

    The benefits of regulated activity in this space are manifold. Markets generate valuable information that can be used for forecasting and decision-making. For instance, regulated platforms like the recent collaboration between Kalshi and Susquehanna International Group enhance market liquidity and confidence, ensuring that participants have reliable data and a secure trading environment.

    However, I am concerned about the recent proposals by the CFTC. The current interpretation undermines the potential benefits these contracts offer for risk management and market transparency. The argument that election event contracts might serve as a tool for election manipulation is not credible. Furthermore, defining these contracts as 'gaming' is wrong and overbroad. Such a stance will likely drive activity offshore to unregulated markets, undermining the very purpose of the CFTC's regulatory oversight. It also ignores the extensive data and research that supports the utility and safety of these contracts.

    Effective regulation requires a collaborative approach. I urge the CFTC to engage more actively with stakeholders, consider the comments from the industry, and do the hard work to understand these markets. Asking the right questions and listening to the industry's needs is crucial for creating a balanced regulatory environment.

    Therefore, I respectfully request the Commission to vote no on the proposed event contract rule and hold a roundtable discussion. This will allow for more comprehensive feedback from the industry and ensure that all perspectives are adequately considered.

    In conclusion, I believe that regulated event contracts are essential for a transparent and efficient marketplace. I appreciate your attention to this matter and look forward to a constructive dialogue on how best to regulate these essential contracts.

    Thank you for your consideration.

    Sincerely,
    Adhi Rajaprabhakaran"

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