Comment on CFTC-2026-1189, CFTC-2026-1189-0001, Devin, Darmody
Devin DarmodySupportIndividual
Summary: Devin Darmody, an individual trader, supports the proposed rule because it maintains a contract-by-contract review process and recognizes that banning contracts may drive users to unregulated offshore markets. He argues that regulated domestic exchanges provide necessary protections and useful price discovery for mainstream sports markets.
Dear Chairman and Commissioners:
My name is Devin Darmody, and Im an everyday citizen from New York who actively trades event contracts on Kalshi and similar platforms. Im writing in support of the proposed rule, Prediction Markets; Public Interest Determinations, RIN 3038-AF65, published at 91 FR 35806.
I especially support the proposals recognition that banning a contract in the United States doesnt eliminate demand. It often pushes traders toward unregulated offshore venues. That practical point should remain front and center in the final rule. If people are going to trade an event, I would much rather see that trading happen on a CFTC-overseen exchange with customer protections, market surveillance, and a regulator that can hold the platform accountable. Offshore sites may offer none of those things. Traders can be left without segregated funds or meaningful recourse if something goes wrong.
The Commission should also keep its contract-by-contract review under Regulation 40.11 and explain the reasons for its decisions. As someone who actually uses these markets, I want clear rules and understandable decisions. Blanket bans make legitimate products disappear without considering how a particular contract works or what information it provides.
I also support the proposals recognition of price discovery and information value. I dont need to be using a contract as a traditional hedge for its price to be useful. Market prices provide a real-time signal about what participants collectively expect. I look at those prices to see how views are changing as new information comes out. Thats useful even when I decide not to place a trade.
The sports markets I follow most closely are straightforward markets on final scores and who wins. These outcomes are objective, public, and easy to verify. The same is true for point spreads and margins of victory, season-long and tournament outcomes, and player or team statistical totals over a game or season. These mainstream sports markets serve the public interest and produce useful information. They belong on well-regulated, CFTC-overseen exchanges.
I understand that the Commission has legitimate concerns about other types of contracts. Im not defending markets based on player injuries, in-game fights or altercations, or youth and pre-collegiate sports. I also support prohibiting contracts on war, death, assassination, and terrorism.
Please finalize the proposed rule while preserving its contract-specific approach, its reasoned public-interest factors, and its recognition that driving traders offshore makes them less safe, not more. A regulated domestic market is the better outcome for ordinary participants like me.
Sincerely,
Devin Darmody