Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Alex, Russell

Alex RussellSupportIndividual
Summary: Alex Russell, a finance professional and prediction market user, supports the proposed rule while urging the CFTC to maintain a contract-by-contract review process. He argues that keeping these markets on regulated exchanges is safer than driving users to offshore platforms and emphasizes the value of price discovery and information.
Dear Chairman and Commissioners: My name is Alex Russell, and Im a finance professional in Nevada. Ive worked in finance, including personal and business taxes, for nearly five years. That work has led me to consider many kinds of investments, including real estate, franchises, stocks, high-yield accounts, crypto, and prediction markets. I actively traded event contracts on Kalshi covering sports, politics, and other topics until access was blocked in Nevada. I support the CFTCs proposed rule, Prediction Markets; Public Interest Determinations, RIN 3038-AF65, and I ask the Commission to preserve its contract-by-contract approach in the final rule. Under Regulation 40.11, each contract should be reviewed on its own facts, with the Commission explaining its reasoning. As someone who actually uses these markets, I want clear and reliable rules. I would rather see the CFTC make a reasoned decision about a particular contract than prohibit an entire category and make useful products disappear without a specific explanation. The proposal is also right to recognize that demand doesnt vanish when a contract is unavailable on a U.S.-regulated exchange. Some traders will move to offshore platforms that lack fund protections, market surveillance, and meaningful recourse. Keeping activity on regulated, CFTC-overseen exchanges is safer and more transparent. I also support the proposals broad view of price discovery and information value. I dont use every contract as a traditional hedge. Sometimes I use prices to understand what market participants collectively think is likely to happen in sports, politics, the economy, or public policy. The changing price gives me useful information, similar to watching a stock price move as new facts come in. My experience with sports contracts is concrete. I had avoided traditional Nevada sports betting apps because I found their offerings limited and their settlement terms different from prediction markets. On Kalshi, I understood that I was buying a contract tied to a stated, factual outcome, and that the contracts value could rise or fall before settlement. After Kalshi became unavailable in Nevada, I switched to MGM for sports betting, but I lost access to the wider range of event markets I had used. Mainstream sports markets based on final scores and winners, point spreads and margins of victory, season-long and tournament outcomes, and player or team statistical totals over a game or season serve the public interest. They settle using objective, publicly verifiable results that no individual trader can control. They also generate useful prices and belong on well-regulated, CFTC-overseen exchanges. I understand the Commission has legitimate concerns about other products. Im not defending contracts on player injuries, in-game fights or altercations, or youth and pre-collegiate sports. I also support prohibiting contracts involving war, death, assassination, and terrorism. Please finalize the proposal while keeping its contract-specific review, reasoned decisions, recognition of offshore displacement, and meaningful consideration of price discovery and information value. Those features would give market users clear rules while protecting the public. Sincerely, Alex Russell

View on Regulations.gov