Jason Ruspini:

Unfortunately, election contracts and ALL event contracts appear to be prohibited by CFTC regulation 40.11, released in July 2011 as part of Dodd-Frank:

“(a) Prohibition. A registered entity shall not list for trading or accept for clearing on or through the registered entity any of the following:

(1) An agreement, contract, transaction, or swap based upon an excluded commodity, as defined in Section 1a(19)(iv) of the Act, that involves, relates to, or references terrorism, assassination, war, gaming, or an activity that is unlawful under any State or Federal law”

“… involves, relates to … an activity that is unlawful under any State or Federal law” is very broad. Not only does it include election outcomes, which several States have explicit laws against, but Massachusetts, Mississippi, Nebraska, North Dakota and South Carolina have laws against bets on “events”.

This is not the only reading of 40.11 and is certainly not the one Nadex holds. In the short term, it seems that any argument for this sort of contract has to address the broad interpretation above all.

We are academic researchers who study prediction markets. We are writing in favor of allowing NADEX, or a similar entity, to offer a broad range of political and policy event futures, including the three they are currently proposing.

There are four broad reasons for our support:

1. Existing political event futures have proven useful. Political event futures have been offered in small quantities by the onshore Iowa Electronic Markets (IEM), and by offshore exchanges such as Intrade. Prices from these markets have made possible a broad range of academic research.

2. Political event futures facilitate price discovery in other asset markets. One of the findings of this research is that firms and industries are exposed to political and policy risk. Political event futures provide investors with a market-based assessment of outcome probabilities, which reduces investors’ uncertainty when trading other assets. In addition, if allowed to operate onshore, political event futures markets might eventually grow to the point where they might provide useful hedging opportunities for firms. The currently proposed position limits are likely sufficient for most individuals to hedge their personal exposure to election outcomes.

3. The full potential of political event futures cannot be realized in academic-scale markets or offshore. Despite the utility of the IEM and Intrade, both markets are hampered by the current regulatory environment. An onshore exchange that allowed positions of the size NADEX is suggesting could ultimately reach a scale where it could attract liquidity to contracts that currently do not succeed on Intrade. There are many exciting potential applications of such markets, in research and policy making. Offering contracts on questions of great popular interest (such as Presidential elections) is crucial to attracting investors to an exchange. Once there, they face lower costs of participating in other markets, such as those currently offered by NADEX.

4. Concerns about gambling and manipulation are misplaced. Trading securities whose payoffs depend on political outcomes is no more “gaming” than trading securities whose payoffs depend on commodity or equity prices. Clearly, one can trade any security out of gambling motives, so the key question is whether the subject of these contracts is a “game,” or an economically important event. It is hard to argue that elections are not economically important events.

One might be concerned with two forms of manipulation: outcome and price manipulation. Many individuals have already large stakes in election outcomes; for example, a top executive in a public company will have will have a significant exposure via their equity holdings, as well as through any impact of the election on policies such as tax rates. Many individuals also have substantial exposure to election outcomes via their careers. Given the position limits proposed by NADEX, the market is likely to make at most a small contribution towards the number of individuals with meaningful stakes in election outcomes. One might be concerned with trading by those involved in supervising elections, and it might be reasonable for policy to prohibit trading by those individuals.

Turning to price manipulation, there have been a couple episodes that appeared to be attempt by traders to influence perceptions of an election by manipulating prediction market prices. The evidence suggests that effects on prices are relative short-lived, and effects on perceptions are often counter-productive for the manipulator (e.g., through media stories mentioning the manipulation). Onshore election markets will likely be significantly more liquid, making price manipulation even less attractive. A further protection comes from the fact that the outcomes of interest (election winners) will be linked to prediction market prices only through perceptions. Concern about price manipulation might be better devoted to cash-settled futures, where contracts settle based on other financial market prices.

To summarize, we view markets in securities contingent on economically-relevant events as an innovation that generate positive externalities (by aggregating information) as well as benefits to participants. Innovations with positive externalities should be encouraged by policy makers, not limited. If the Commission has questions about any of the statements made or research mentioned in this letter, it should feel free to contact any of the undersigned.

For info, here’s the Midas Oracle feed at Twitter. I publish there plenty of prediction market news that don’t appear on this blog.

Philip Tetlock:

More.

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“A financial adviser or stock broker should be licensed to provide any consultation on investment in securities.”

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The intelligence and security community also has mixed views. John F McCreary, the Chief Analysis Officer for KGS Security, who had a senior role at the United States Defense Intelligence Agency, notes that the National Intelligence Council successfully trialed prediction markets, until political pressure ended the experiment. However, he believes that, since they “violate the scientific principles of auditability, replicability and irrefutability”, they lack credibility. Retired Naval Intelligence Commander Jennifer Dyer sceptically points out that, “anyone who has bet on sports would be wary of the effects of a large, very specifically motivated group of bettors”. According to Professor Anthony Glees of the University of Buckingham, “there must be a few analysts in the FCO and at GCHQ looking at these sorts of websites but I doubt if they spend much time on them”.

See also the excellent analysis of Mike Smithson.

We conducted laboratory experiments for analyzing the accuracy of three structured approaches (nominal groups, Delphi, and prediction markets) relative to traditional face-to-face meetings (FTF). We recruited 227 participants (11 groups per method) who were required to solve a quantitative judgment task that did not involve distributed knowledge. This task consisted of ten factual questions, which required percentage estimates. While we did not find statistically significant differences in accuracy between the four methods overall, the results differed somewhat at the individual question level. Delphi was as accurate as FTF for eight questions and outperformed FTF for two questions. By comparison, prediction markets did not outperform FTF for any of the questions and were inferior for three questions. The relative performances of nominal groups and FTF were mixed and the differences were small. We also compared the results from the three structured approaches to prior individual estimates and staticized groups. The three structured approaches were more accurate than participants’ prior individual estimates. Delphi was also more accurate than staticized groups. Nominal groups and prediction markets provided little additional value relative to a simple average of the forecasts. In addition, we examined participants’ perceptions of the group and the group process. The participants rated personal communications more favorably than computer-mediated interactions. The group interactions in FTF and nominal groups were perceived as being highly cooperative and effective. Prediction markets were rated least favourably: prediction market participants were least satisfied with the group process and perceived their method as the most difficult.