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Comment for Proposed Rule 89 FR 48968

  • From: Paul Bellan-Boyer
    Organization(s):
    Private citizen

    Comment No: 74350
    Date: 8/7/2024

    Comment Text:

    I would like to comment specifically about mis-identifying election futures contracts as gaming.

    I have experience in these markets, having participated in several forums over multiple election cycles. I also have experience as a personal investor in other security instruments: stocks, ETFs, iindex funds, options, fixed income.

    I also have 12 yrs experience designing and administering computer systems for equities and their derivatives for a large investment firm (not my current work). And in that work, I experienced how those securities were traded - not "gamed."

    Gaming and securities trading both involve risk. But in my experience, predictive markets for elections do not resemble gaming, but the markets for other, more commonly accepted securities.

    Predictive markets track how the market participants gauge risk and reward for knowable, real-world events. A futures contract on a commodity does this for the price of a tangible commodity, which is influenced widely-known factors (supply and demand, the weather in crop-producing regions, actions of governments, etc), even if different actors with different information may evaluate the risks and rewards differently. They are also influenced by generally unknown, or less appreciated factors (a global pandemic, a war affecting commodity production and shipments, etc).

    Election futures are much more similar to commodity futures. There are widely known factors (past results of candidates and parties, current polling, issues, efforts to enlist or turnout voters, etc.) And unappreciated factors (a candidate unexpectedly withdraws, an economic or geopolitical event changes opinions about their vote, etc).

    Election futures may be used for speculation, just like other futures and financial instruments. But they function more like investments than bets, and have predictive value. Unlike gaming, studies show that predictive markets are pretty good predictors of election results, just as futures and options markets are pretty good predictors of future prices.

    I ask you to reject this rule and the idea that election futures are gaming.

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