CFTC regulation and election contracts

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Insofar as event markets are within the CFTC&#8217-s jurisdiction, they would likely be approved as &#8220-excluded commodities&#8221-. Here is the relevant part of the definition within the Commodity Exchange Act:

(iv) an occurrence, extent of an occurrence, or contingency (other than a change in the price, rate, value, or level of a commodity not described in clause (i))
that is—
(I) beyond the control of the parties to the relevant contract, agreement, or transaction- and
(II) associated with a financial, commercial, or economic consequence.

With the putative terrorism and assassination markets, by their nature, it is impossible to reliably identify who might manipulate an outcome. It could be argued then that such contracts do not involve commodities and lie outside the jurisdiction of the CFTC.* The counterargument is that such markets are actually &#8220-exempt commodities&#8221-, defined broadly in the CEA as &#8220-all non-agricultural, non-excluded commodities&#8221-. This is something for the CFTC to clarify: are event markets &#8220-excluded commodities&#8221-, &#8220-exempt commodities&#8221-, or might they fall into either category depending on their specifics? Examples of exempt commodities are energy products, metals and quasi-currencies like energy, bandwidth and carbon credits. In practice then, if not by law, exempt commodities have involved something deliverable in units other than cash, although specific contracts might also be cash-settled.

It is a good bet then that the CFTC would classify event markets as excluded commodities. Additionally, invoking the &#8220-beyond the control&#8221- clause would be a very antiseptic way for the agency to repudiate markets based on terrorist events and the like, although they would risk losing the ability to punish similar markets that do not meet all criteria. Putting that issue aside for a moment and considering only the CFTC&#8217-s approval process, this treatment would bring up two problems with markets that the agency might want to regulate. Each of these problems has a solution.

First, wouldn&#8217-t election and policy markets also be disqualified by the clause? After all, a candidate could throw an election for profit, or perhaps more likely, engage in some sort of &#8220-point shaving&#8221-. Remember, these are not securities and thus not subject to insider-trading laws. The CEA, however, includes a section 13(f) prohibiting members of exchanges from trading on material nonpublic information obtained through their exchange duties. It is feasible to create similar trading restrictions at the regulatory level, by disallowing candidates, their staffs and proxies from trading.

Such trading prohibitions would reasonably ensure that no trader would be in control of the outcome of the contract. The CFTC could levy a special trading fee (much less than 1% notional) on such contracts to offset the relative work they might entail. The framework for such an arrangement could possibly be clarified on the CFTC&#8217-s next reauthorization. In a sense, it was unfortunate that their request for comments on event markets came so late in their recent reauthorization process. From another perspective, they ostensibly have until 2013 to exercise innovative, progressive policy.

Now, what if someone not barred from trading possesses damning information, photos, etc, on a candidate? By deciding whether or not to release that information, are they then &#8220-in control&#8221- of the contract&#8217-s outcome? It&#8217-s doubtful. Even though they might influence the contract&#8217-s outcome, they are not &#8220-in control&#8221- of it. The situation is similar to whether or not a trader, who might be aware of a new oil find or simply has a large account, is in control of that non-&#8221-excluded&#8221- commodity price. In general, the rules should be designed to elicit as much information as possible, falling short of allowing traders to decide a 0 or 100 settlement.

The second issue is the implicit assassination option in candidates&#8217- contract prices.** This issue could be easily dealt with, as Intrade does with their updated rules. Clearly this would be necessary with CFTC-regulated contracts, or else an unknown might be in control of their outcomes. The CFTC rule might work as follows. Upon a death, all contracts would be immediately cash-settled at their last price before the event. As soon as possible, an updated set of contracts would then begin trading so that no trader is able to profit or lose from the jump in prices. This process would be similar to traders simply rolling into a new contract maturity. It would be disruptive, but nothing to complain about compared to the tragedy of the situation. Small modifications to the rule could address scenarios where a candidate is incapacitated for some time during which their candidacy is uncertain.

A more challenging scenario is the possibility of a manipulation preceding the event such that the forced settlement locks-in profits, presumably just as market power is exhausted. Regulations could provide for an investigation of such situations, and the relevant transactions and profits shouldn&#8217-t be too hard to find with that level of scrutiny.

This framework addresses several of the questions posed in the CFTC&#8217-s concept release. That document and comments elsewhere seem to indicate a reluctance to expand jurisdiction to the point where sports markets and gaming might be included. Officials now and then harken back to the pre-CFMA economic purpose test, but that test could be effectively reconstituted for event markets with a policy decision such that those markets will only be approved as excluded commodities, subject to their specific &#8220-economic consequence&#8221- clause. In itself, that policy would not impinge on the agency&#8217-s ability to prosecute unauthorized exchanges in similar markets (and hopefully they will treat Intrade with some degree of amnesty given the ambiguous and arbitrary law of this country). While this policy would leave the door open even for regulated sports-based hedging markets, the CFTC could leave the prosecution of online sports and gaming exchanges to the DOJ and state authorities for now. The burden of the duty to prosecute illegally operating exchanges might be smaller than feared, and, again, the agency could levy a special fee on such regulated markets to offset demands on its resources.

These opinions perhaps pose more questions than they answer. The Commodity Exchange Act is broad enough to encompass jurisdiction over event markets. The CFTC seems unsettled that the language is too broad, but there are ways for them to calibrate their jurisdiction at the policy level.

* A market in research science claims would follow the same logic in terms of jurisdiction. Even without a no-action letter or public interest exemption, the chances seem very good that such an exchange could operate without interference if they stayed with small claims, did not advertise and did not accept trades from States where the predominant factor test does not apply.

** Let me condemn Hillary Clinton&#8217-s recent remarks as sinister and irresponsible.

Cross-Posted from RM&amp-P

Did Patri Friedman misread BetFair?

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About the latest New York Times story on BetFair fighting sports corruption&#8230-

Patri Friedman:

Prediction markets not only make fixing easier to profit from, by creating a liquid market for insider betting, but they also make it easier to detect, by creating a centralized database of betting for analysis: […]

So. the effects are mixed, and in the end we are left with the Homer Simpson-esque paradox that prediction markets are both the cause of, and the solution to, insider trading.

Hell, no.

My remarks about his 2 statements:

#2. Sports betting (thru bookmakers and sportsbooks) existed well before the apparition of the prediction exchanges (betting exchanges) &#8212-BetFair was created in 1999 and was launched in 2000, and TradeSports, in 2002.

#1. More money is bet on sports with bookmakers than with prediction exchanges (betting exchanges).

  1. Match fixing existed before betting.
  2. Profiting from match fixing existed before BetFair and TradeSports.
  3. BetFair is the only betting company in the world that has systematized a cooperation program with sports bodies in order to detect and fight sports corruption.

Consensus Point wins… NewsFutures and others lose…

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David Perry (of Consensus Point) has just clinched a deal.

I have told you many times that David Perry is a very gifted salesperson and business executive. Under-rate him at your own risk.

UPDATE: I&#8217-m told it&#8217-s a nano deal. :-D

Using Prediction Markets to Track Information Flows: Evidence from Google – VIDEO – Bo Cowgill on Googles enterprise prediction markets – OReilly Money:Tech

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Using Prediction Markets to Track Information Flows: Evidence from Google – (PDF file – PDF file) – by Bo Cowgill, Justin Wolfers, and Eric Zitwewitz – 2008-01-06

Via Daniel Horowitz (Business and Technology Consultant)

Blip.TV &#8212- (FLV file)

It&#8217-s cool. :-D

Google Web Search

Using Prediction Markets to Track Information Flows: Evidence from Google – (PDF file – PDF file) – by Bo Cowgill, Justin Wolfers, and Eric Zitwewitz – 2008-01-06

ABSTRACT: In the last 2.5 years, Google has conducted the largest corporate experiment with prediction markets we are aware of. In this paper, we illustrate how markets can be used to study how an organization processes information. We document a number of biases in Google’s markets, most notably an optimistic bias. Newly hired employees are on the optimistic side of these markets, and optimistic biases are significantly more pronounced on days when Google stock is appreciating. We find strong correlations in trading for those who sit within a few feet of one another- social networks and work relationships also play a secondary explanatory role. The results are interesting in light of recent research on the role of optimism in entrepreneurial firms, as well as recent work on the importance of geographical and social proximity in explaining information flows in firms and markets.

DISCUSSION: In the past few years, many companies have experimented with prediction markets. In this paper, we analyze the largest such experiment we are aware of. We find that prices in Google’s markets closely approximated event probabilities, but did contain some biases, especially early in our sample. The most interesting of these was an optimism bias, which was more pronounced for subjects under the control of Google employees, such as would a project be completed on time or would a particular office be opened. Optimism was more present in the trading of newly hired employees, and was significantly more pronounced on and immediately following days with Google stock price appreciation. Our optimism results are interesting given the role that optimism is often thought to play in motivation and the success of entrepreneurial firms. They raise the possibility of a “stock price-optimism-performance-stock price” feedback that may be worthy of further investigation. We also examine how information and beliefs about prediction market topics move around an organization. We find a significant role for micro-geography. The trading of physically proximate employees is correlated, and only becomes correlated after the employees begin to sit near each other, suggesting a causal relationship. Work and social connections play a detectable but significantly smaller role.

An important caveat to our results is that they tell us about information flows about prediction market subjects, many of which are ancillary to employees’ main jobs. This may explain why physical proximity matters so much more than work relationships – if prediction market topics are lower-priority subjects on which to exchange information, then information exchange may require the opportunities for low-opportunity-cost communication created by physical proximity. Of course, introspection suggests that genuinely creative ideas often arise from such low-opportunity-cost communication. Google’s frequent office moves and emphasis on product innovation may provide an ideal testing ground in which to better understand the creative process.

PAPER BODY: In the last 4 years, many large firms have begun experimenting with internal prediction markets run among their employees. The primary goal of these markets is to generate predictions that efficiently aggregate many employees’ information and augment existing forecasting methods. […] In this paper, we argue that in addition to making predictions, internal prediction can provide insight into how organizations process information. Prediction markets provide employees with incentives for truthful revelation and can capture changes in opinion at a much higher frequency than surveys, allowing one to track how information moves around an organization and how it responds to external events. […]

We can draw two main conclusions. The first is that Google’s markets, while reasonably efficient, reveal some biases. During our study period, the internal markets overpriced securities tied to optimistic outcomes by 10 percentage points. The optimistic bias in Google’s markets was significantly greater on and following days when Google stock appreciated. Securities tied to extreme outcomes were underpriced by a smaller magnitude, and favorites were also overpriced slightly. These biases in prices were partly driven by the trading of newly hired employees- Google employees with longer tenure and more experience trading in the markets were better calibrated. Perhaps as a result, the pricing biases in Google’s markets declined over our sample period, suggesting that corporate prediction markets may perform better as collective experience increases.

The second conclusion is that opinions on specific topics are correlated among employees who are proximate in some sense. Physical proximity was the most important of the forms of proximity we studied. Physical proximity needed to be extremely close for it to matter. Using data on the precise latitude and longitude of employees’ offices, we found that prediction market positions were most correlated among employees sharing an office, that correlations declined with distance for employees on the same floor of a building, and that employees on different floors of the same building were no more correlated than employees in different cities.4 Google employees moved offices extremely frequently during our sample period (in the US, approximately once every 90 days), and we are able to use these office moves to show that our results are not simply the result of like-minded individuals being seated together. […]

Our findings contribute to three quite different literatures: on the role of optimism in entrepreneurial firms, on employee communication in organizations, and on social networks and information flows among investors. […]

The lessons of the literature informed Google CEO Eric Schmidt and Chief Economist Hal Varian’s (2005) third rule for managing knowledge workers: “Pack Them In.” Indeed, the fact that Google employees moved so frequently during our sample period suggests that considerable thought is put into optimizing physical locations. To this literature, which has largely relied on retrospective surveys to track communication, we illustrate how prediction markets can be used as high-frequency, market-incentivized surveys to track information flows in real-time. […]

Google’s prediction markets were launched in April 2005. The [Google prediction] markets are patterned on the Iowa Electronic Markets (Berg, et. al., 2001). In Google’s terminology, a market asks a question (e.g., “how many users will Gmail have?”) that has 2-5 possible mutually exclusive and completely exhaustive answers (e.g., “Fewer than X users”, “Between X and Y”, and “More than Y”). Each answer corresponds to a security that is worth a unit of currency (called a “Gooble”) if the answer turns out to be correct (and zero otherwise). Trade is conducted via a continuous double auction in each security. As on the IEM, short selling is not allowed– traders can instead exchange a Gooble for a complete set of securities and then sell the ones they choose. Likewise, they can exchange complete set of securities for currency. There is no automated market maker, but several employees did create robotic traders that sometimes played this role.

Each calendar quarter from 2005Q2 to 2007Q3 about 25-30 different markets were created. Participants received a fresh endowment of Goobles which they could invest in securities. The markets’ questions were designed so that they could all be resolved by the end of the quarter. At the end of the quarter, Goobles were converted into raffle tickets and prizes were raffled off. The prize budget was $10,000 per quarter, or about $25-100 per active trader (depending on the number active in a particular quarter). Participation was open to active employees and some contractors and vendors– out of 6,425 employees who had a prediction market account, 1,463 placed at least one trade. […]

Common types of markets included those forecasting demand (e.g., the number of users for a product) and internal performance (e.g., a product’s quality rating, whether a product would leave beta on time). […]

In addition, about 30 percent of Google’s markets were so-called “fun” markets –markets on subjects of interest to its employees but with no clear connection to its business (e.g., the quality of Star Wars Episode III, gas prices, the federal funds rate). Other firms experimenting with prediction markets that we are aware of have avoided these markets, perhaps out of fear of appearing unserious. Interestingly, we find that volume in “fun” and “serious” markets are positively correlated (at the daily, weekly, and monthly frequencies), suggesting that the former might help create, rather than crowd out, liquidity for the latter. […]

Google’s prediction markets are reasonably efficient, but did exhibit four specific biases: an overpricing of favorites, short aversion, optimism, and an underpricing of extreme outcomes. New employees and inexperienced traders appear to suffer more from these biases, and as market participants gained experience over the course of our sample period, the biases become less pronounced. […]

FOOT NOTE: One trader in Google’s markets wrote a trading robot that was extremely prolific and ended up participating in about half of all trades. Many of these trades exploited arbitrage opportunities available from simultaneously selling all securities in a bundle. In order to avoid having this trader dominate the (trade-weighted) results in Table 9, we include a dummy variable to control for him or her. None of the results discussed in the above paragraph are sensitive to removing this dummy variable.

APPENDIX:

Google Chart 1

Google Chart 2

Bo Cowgill&#8217-s precision point on micro-geography:

Below you can see a snapshot of trading in one of our offices. The areas where employees are making profitable decisions is green, and the areas where employees are making unprofitable decisions is red. There are about 16 profitable traders in that big green blotch in the middle!

Chart of the Day: Information Sharing at Google

More information from our previous blog post on the Google paper

Using Prediction Markets to Track Information Flows: Evidence from Google – (PDF file – PDF file) – by Bo Cowgill, Justin Wolfers, and Eric Zitwewitz – 2008-01-06

Reverse engineering of a nasty BetFair rumor that made rounds on Midas Oracle and elsewhere

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  1. The Sporting Exchange (BetFair-TradeFair) is a gaming company that operates on many countries.
  2. It would happen, occasionally, that one country&#8217-s laws would allow fixed-odds bookmakers &#8212-but not betting exchanges.
  3. BetFair would still want to operate in that country &#8211-as a bookmaker, not as a prediction exchange&#8211- to have its name out there &#8212-with the long-term goal of reverting it to a full exchange, once the laws will have been modified, later on, in the future.
  4. To do so, in the summer of 2007, BetFair began to hire people to provide prices and manage risk for that Internet sportsbook. That sportsbook has no connection whatsoever with the UK betting exchange.
  5. One un-hired job candidate told everyone who would listen that BetFair was preparing to do some hidden market-making on their betting exchange &#8212-hiring a &#8220-team of traders&#8221-.
  6. BetFair wouldn&#8217-t deny those allegations, out of fear of hinting its competitors.
  7. The sportbook, which was at the origin of that market-making rumor, is BetFair Italy &#8212-which has opened shop recently.

If you want to increase the absolute accuracy of the outputs of the prediction markets, try (if you can) to increase the quality of the inputs.

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Wanna better political prediction markets? Ask Gallup to generate better polls &#8212-because that&#8217-s what traders eat for breakfast.

I have been telling that to Barry Ritholtz &#8212-but he stays on his position.

Thanks to Barry for listening.

Let&#8217-s move on to another polemique.

Ubber finance blogger Barry Ritholtz believes in magic. He believes that, with more volumes on the event derivative markets, comes the Omniscience -capital O.

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Our good friend Barry Ritholtz.has persuaded himself that our real-money prediction markets suffer from an irremediable and fatal problem: liquidity on political event derivative markets is too thin for smart Wall Street people like him to take their market-generated probabilities seriously. Barry Ritholtz is keen to tout oranges&#8211-apples comparisons: the NYSE volume versus the Obama&#8211-Clinton volume at InTrade. It&#8217-s a bullshit argument, but he managed to persuade some gullible journalists writing for some clueless mainstream media that thin liquidity was responsible for the New Hampshire upset &#8212-and else.

Barry, if you had 1,000,000,000 trades on the New Hampshire prediction market, you&#8217-d still have an inaccurate prediction. The polls were wrong, and there&#8217-s nothing &#8230- NOTHING&#8230- that the InTrade and BetFair traders could have done to get this election right. Get over it, Barry. Traders are not magicians. :-D

[For why the polls were wrong, see: The New York Times, Zogby, Rasmussen, Gallup…]

Prediction markets = the future of journalism -said, from day one, Emile Servan-Schreiber of NewsFutures. Emile, if you have balls, lets do it -all together.

My yesterday&#8217-s post about the Obama&#8211-Clinton prediction markets was the most popular Midas Oracle story of that Monday. Hummmm&#8230- No idea why&#8230- I was not helped by Google Search or by an external blogger. Sounds like our Midas Oracle web readers and feed subscribers liked it &#8230- for some reasons I have yet to discover fully.

Anyway.

  1. I&#8217-m minding a grand &#8220-Midas Oracle Project&#8220-, and you can join it.
  2. Emile believes that prediction markets represent &#8220-the future of journalism&#8220-. I am trying to mind, specifically, what form could take the &#8220-prediction market journalism&#8220-.
  3. The idea is this: We need to put the charts of prediction markets inside news stories, and those stories should incorporate the meaning of the probability fluctuations (a la Justin Wolfers).
  4. If we stay in our armchairs, nothing will happen, because most of the old-school journalists and bloggers don&#8217-t think much of the prediction markets. The prediction market infiltration in the Mediasphere and the Blogosphere is like a weak stream, right now. I don&#8217-t have the patience to wait until &#8220-2020&#8243-.
  5. I don&#8217-t think that much will come out of the prediction exchanges. The BetFair blog and the InTrade newsletter are 2 pieces of crap &#8212-they compete in content quality with the Mongolian edition of the News Of The World.
  6. If you look at the evolution of the media, you see that the old-school, dead-tree publications are slowly dying, and are replaced by professional blog networks &#8212-look especially in the IT industry, with TechCrunch, etc. What you have is writers who publish only for the Web, and who fill a vertical niche. (And, the Washington Post is now publishing content from&#8230- guess who.)
  7. Needless to say, prediction market journalism is costly. Now, go directly to point #8, because that&#8217-s where the beef is.
  8. Yes, I have &#8220-heard of Christmas&#8221- :-D , and I understand Robin Hanson&#8217-s reasoning. [*] That&#8217-s where my funding idea lays. The idea is to think hard about who &#8220-might actually be willing to pay&#8221-. I am thinking of a class or organizations that &#8220-might actually be willing to pay&#8221-, provided 2 things. Number one, that I operate a certain twist on my form of prediction market journalism. Number two, that this project becomes the project of many prediction market people, or, better, of the whole prediction market industry &#8212-not just Chris Masse&#8217-s one. Those 2 things are essential.
  9. So, Emile, wanna join the &#8220-Midas Oracle Project&#8220-?

[*] APPENDIX:

The &#8220-high IQ&#8221- Robin Hanson:

Chris, you’ve heard of Christmas I presume. Many people circulate lists of items they might like for Christmas. If you did, would you circulate a list of million franc/dollar gift ideas for people to give you? Would you consider that list more honest/logical than a list of gifts of roughly the price you think others might actually be willing to pay?

Robin Hanson would be better off lobbying for prediction markets with the people who will be in power next November -that is, the Democrats, not the right-wing people of the American Enterprise Institute.

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Does Robin Hanson read the political prediction markets which he co-invented? If he read them, he would see that we&#8217-re going to get a big Democratic swipe, in November 2008. The American people will get rid of the neo-cons, the warmongers, and other right-wing nuts.

Then, if you wanted to &#8220-lobby&#8221- for the prediction markets, you would get your message thru using either a Democratic or bi-partisan vehicle &#8212-not the right-wing American Enterprise Institute. What weight will those right-wing people carry next November? They&#8217-ll be finished &#8212-until a brand-new Newt Gingrich alike pops up in the years 2020.

Get a ride in K Street with the right people, doc &#8212-that is, in our case, like it or not, the leftists.

The managing editor of CNBC.com asks readers whether they should report what the (play-money and real-money) prediction markets say. He is not that hot on the idea -to say the least. Which is why we should develop a blog network on prediction markets -to get rid of the journalists filter and report

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But the &#8220-gambling&#8221- nature puts some journalists off.

Is it just providing information &#8230- or promoting betting action?

See, that&#8217-s exactly why I want to develop my &#8220-Midas Oracle Project&#8221-.

Classic journalists and classic bloggers will never treat prediction markets with the maximum sophistication they deserve.

Only brand-new blog networks that will specialize in prediction markets will do a good job.

I&#8217-ll provide more details soon.

I hope that some of you will join this project. It should be a collective endeavor.

E-mail me to join.