Comment on CFTC-2026-0331, CFTC-2026-0331-0001, Sarah, Nom
Sarah NomSupportIndividual
Summary: The commenter supports the Commission clarifying rules for prediction markets but argues that further rulemaking is necessary to ensure fairness. They specifically call for regulations that mandate equal access to API endpoints and information for all market participants to prevent advantages for institutional partners.
Prediction markets serve a valuable purpose in providing useful forecasts and the ability to hedge. I support the Commission clarifying the rules around them.
However, for prediction markets to be fair and open markets, further rulemaking and enforcement from the Commission is required.
The currently operating prediction markets are offering disintermediated trading. This has benefits, but it the way that it has been implemented poses risks to fairness.
Kalshi for example has some application programming interface (API) endpoints that only their institutional partners can access. This creates an unfair playing field. Other venues are even worse and prohibit regular users that are not their partners from even simple order types like limit orders.
The commission should also ensure that the prediction markets share information equally with all market participants. Currently, Kalshi and others have private chatrooms where they talk to select partners, which gives an unfair informational advantage and does not allow for a fair and open market.
The Commission should regulate and enforce equal access to the same API endpoints and the same information to ALL MEMBERS/market participants -- not the current UNEQUAL ACCESS to APIs, rate limits and other information.