Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Ann, Gullo

Commodity Futures Trading Commission ,I oppose this rule to deregulate prediction markets like Kalshi and Polymarket. The proposed rule rests on a definitional sleight of hand: by narrowly defining gaming as activity involving recreation, rules, and outcomes determined by luck, skill, or athletic ability, the Commission narrows its own authority to act against products that are, by every available measure, online gambling dressed in the language of derivatives markets. A widely cited analysis shows that 0.04 percent of traders captured nearly 70 percent of profits, a wealth distribution that does not describe an information market and does describe a casino. The marketing reflects it: Kalshi ran advertisements claiming sports betting is legal in all 50 states, which it is not, and its CEO publicly tweeted that participants had ninety minutes left to attempt generational wealth over a billion-dollar March Madness bracket. Polymarket ran a free grocery store in New York as a public relations stunt while its CEO described the company's long-term vision as financializing everything. The people on the losing end are not abstract: users on the Kalshi subreddit describe taking loans, draining retirement accounts, falling behind on rent, and losing the money they had been trying to use to help family. The proposed rule ignores those victims.The insider trading problem the Commission claims to be managing cannot be managed, and the political economy of the rulemaking deserves scrutiny. The platforms' own theory, articulated by the academic founders of the field, is that they want as many insiders trading as possible because insiders are what make the markets accurate, which means these markets are designed to reward people with non-public information and to extract money from everyone else. Surveillance and identity verification cannot change that, because the relevant insiders are tens of thousands of government employees, corporate staff, and their associates whose information cannot be kept out by any plausible compliance regime.Donald Trump Jr. is reported to be a strategic advisor to both Kalshi and Polymarket, the Commission's chairman has publicly defended these platforms against state regulators, and more than a dozen states are currently suing Kalshi for offering unlicensed gambling. The Commission should not finalize a rule that ratifies the platforms' preferred framework while these lawsuits proceed.For these reasons, we urge the Commission not to finalize the proposed rule. If the Commission proceeds, the final rule should at minimum require the same consumer protections as are imposed on state-regulated sportsbooks, including problem gambling tools, deposit limits, self-exclusion programs, advertising restrictions modeled on tobacco regulation, and a minimum age of 21. The Commission should make clear that the Commodity Exchange Act does not preempt state consumer protection law applicable to retail-facing event contracts, and it should acknowledge that regulating online gambling is not what the CFTC was built to do. The platforms chose CFTC registration because it is the cheapest framework available to them, and the public is entitled to a rule that takes their harm seriously rather than one that ratifies their arbitrage.Sincerely, Ann Gulloamgullo730@gmail.com2051 Mountain Road Larksville , Pennsylvania 18651