Tag Archives: betting markets

The lawyerly questions that the CFTC are asking to Tom W. Bell

Posted on by
8

No Gravatar

CFTC – (PDF file):

CFTC&#8217-s Concept Release on the Appropriate Regulatory Treatment of Event Contracts

–

V. Issues for Comment

A. Request for Comment

The following questions consider the Commission&#8217-s regulatory purview over event contracts, the interests that may appropriately underlie Commission-regulated transactions, and the appropriate regulatory treatment of event contracts. The Commission encourages comments on the specific questions posed, as well as the broad range of issues raised in this concept release. In providing comments, please describe your relevant experience and discuss in detail the facts and legal provisions that support your conclusions. Furthermore, please consider the Commission&#8217-s mandate to protect commodity futures and options markets and customers, and ensure the integrity of the commodity derivatives marketplace, as well as the expected effects of any Commission action on competition, efficiency, innovation and the financial integrity of transactions. Any recommendation with respect to the regulatory treatment of event contracts and markets should be consistent with and supported by the Act, practical, and amenable to effective and efficient implementation.

B. Public Interest

1. What public interests are served by event contracts that are designed and will principally be traded for information aggregation purposes and not for commercial risk management or pricing purposes?

2. How are these interests consistent with the public interest goals embodied in the Act?

3. What calculations, analyses, variables, and factors could be used to objectively determine the social value of information to the general public that may be discovered through trading in event contracts? Should this be a factor in determining whether the Commission plays a role in regulating these markets?

C. Jurisdictional Determinations

4. What characteristics or traits are common to or should be used to identify event contracts and event markets?

5. How do these characteristics and traits differ from those of commodity futures and options contracts that customarily have been regulated by the Commission? How are they similar?

6. Are there criteria based on the provisions of the Act that could be used to make jurisdictional determinations with respect to event contracts and markets?

7. Given the purposes and history of the Act, would it be appropriate for the Commission to apply a test premised on commercial risk management or pricing functions to demarcate the Commission&#8217-s jurisdiction over particular contracts? If so, what factors could be used to make such a determination?

8. Given the purposes and history of the Act, would it be appropriate for the Commission to apply any test premised on the economic purpose of certain types of transactions to demarcate the Commission&#8217-s jurisdiction over particular contracts? If so, what factors could be used to make such a determination?

9. What calculations, analyses, variables and factors would be appropriate in determining whether the impact of an occurrence or contingency will result in a financial, commercial or economic consequence that is identified in Section 1a(13) of the Act?

10. What calculations, analyses, variables, and factors would be appropriate in determining whether an economic or commercial index that is based on prices, rates, values, or levels should or should not qualify as an excluded commodity under Section 1a(13) of the Act?

11. What identifiable factors, statutorily based or otherwise, limit the events and measures that may underlie event contracts when such contracts are treated as Commission-regulated transactions?

12. What objective and readily identifiable factors, statutorily based or otherwise, could be used to distinguish event contracts that could appropriately be traded under Commission oversight from transactions that may be viewed as the functional equivalent of gambling?

13. The Commission notes that Section 12(e) of the Act generally provides that the CEA supersedes and preempts other laws, including state and local gaming and bucket shop laws, with respect to transactions executed on or subject to the rules of a Commission-regulated market, or with respect to transactions exempted from the Act pursuant to the Commission&#8217-s exemptive authority under Section 4(c) of the Act. What are the implications of possibly preempting state gaming laws with respect to event contracts and markets that are treated as Commission-regulated or exempted transactions?

14. Should certain underlying events or measures &#8211-such as those based on assassinations or terrorist activities&#8211- be prohibited altogether due to the social perception and impact of such events? What statutory or other legal basis would support this treatment?

15. Are there event contracts, such as political event contracts, that should be prohibited from trading under the Act, or that deserve separate treatment or consideration, due to the nature and importance of their outcomes? What statutory or other legal basis would support this treatment?

D. Legal Implementation

16. Is it appropriate for the Commission to direct certain or all event contracts onto markets that are regulated differently from and perhaps less stringently than DCMs? For example, it may be warranted or necessary to treat event markets that aggregate information solely for academic or research purposes, event markets set-up for internal corporate purposes, or event markets that offer exceedingly low notional value contracts to traders differently than markets that possess the attributes of traditional DCMs.

17. Is it appropriate for the Commission to use the Section 4(c) exemptive authority of the Act for implementing a regulatory scheme for event contracts and markets? In this regard, the Commission notes that it has the discretion to grant an exemption under Section 4(c) to certain classes of transactions without having to make a determination as to whether such transactions are subject to the Act in the first instance.

18. Is the issuance of staff no-action relief, such as the relief issued to the IEM, an appropriate or preferable means for establishing regulatory certainty for event contracts and markets? Is a policy statement appropriate or preferable?

19. What are the benefits and drawbacks of permitting certain event markets to operate pursuant to Commission established conditions that are similar to the conditions under which the IEM operates?

E. Market Participants

20. Would it be appropriate to allow market participants, and in particular, retail customers, to trade on Commission-regulated event markets with the knowledge that the Commission may not be able to effectively monitor the measures or events that underlie certain event contracts?

21. What unique protections and prophylactic measures are appropriate or necessary for the protection of retail users of event contracts and markets?

22. What are the implications of permitting the intermediation of event contracts, including intermediation on behalf of retail market participants, both with respect to trade execution and clearing?

23. Are there any types of trader or intermediary conduct, peculiar to event contracts and markets, that should be prohibited or monitored closely by regulators?

24. What other factors could impact the Commission&#8217-s ability, given its limited resources, to properly oversee or monitor trading in event contracts?

The term event markets sucks -and the uncritical thinkers using this crappy term suck too.

Posted on by
1

No Gravatar

Google: &#8220-event markets&#8221- &#8212- Funny enough, the first link is to the Futures Industry Association, which promoted the term&#8230- and the second to CFM, which advises not to use that term (see the bottom of the CFM frontpage). :-D

–

Just because 2 or 3 bureaucrats at the CFTC have decided to use that term does not mean that that term makes sense. It does not. &#8220-Event derivative markets&#8221- or &#8220-prediction markets&#8221- are better terms. It&#8217-s with great displeasure that I saw our own Mike Giberson (supposedly, a libertarian, and supposedly, a wannabe academic) followed the step of the CFTC like an obedient little poodle. :-D

–

Just because somebody in power says something stupid that makes no sense at all does not mean that you should swallow it and direct it straight to your stomach.

Use your brain to perform critical reasoning.

–

The best research papers on prediction markets

Posted on by
Reply

No Gravatar

As seen by Andreas Graefe&#8230-

IIF’s SIG on Prediction Markets

Research Papers

Basics

Several studies explain the concept of prediction markets and provide useful summaries of the method, e.g.

– Spann, M. &amp- Skiera, B. (2003). Internet-based Virtual Stock Markets for Business Forecasting, Management Science, 49, 1310-1326. [Full text]
– Wolfers, J. &amp- Zitzewitz, E. (2006). Prediction Markets in Theory and Practice, New Palgrave Dictionary of Economics and the Law (in press). [Full text]
– Wolfers, J. &amp- Zitzewitz, E. (2004). Prediction Markets, Journal of Economic Perspectives, 18, 107-126. [Full text]
– An overview and classification of 152 studies on prediction markets, published between 1991 and 2006, is provided by
Tziralis, G. &amp- Tatsiopoulos (2007). Prediction Markets: An Extended Literature Review, Journal of Prediction Markets, 1, 75-91. [Full text]

Evidence on the accuracy of prediction markets

This section summarizes research that analyzes the relative performance of prediction markets and other forecasting methods.

Markets vs. polls (election forecasting)

– Berg, J., Nelson, F. &amp- Rietz, T. (2008). Prediction Market Accuracy in the Long Run, International Journal of Forecasting, 24, 283-298. [full text]
– Erikson R. S. &amp- Wlezien C. (2007). Are Political Markets Really Superior to Polls as Election Predictors? Public Opinion Quarterly, forthcoming. [full text]
– Stix, G. (2008): When Markets Beat the Polls, Scientific American Magazine, March 2008. [Abstract]

Markets vs. unaided experts and groups

– Pennock, D. M., Lawrence, S., Giles, C.L. &amp- Nielsen, F.A. (2000). The Power of Play: Efficiency and Forecast Accuracy in Web Market Games, Technical Report 2000-168, NEC Research Institute. [full text]
– For predicting Oscar Award winners, Pennock et al. (2000) compared prices of the Hollywood Stock exchange to expert judgments of five movie columnists. On the day the experts revealed their forecasts, only one of them was better than the market predictions. From the day after, the market outperformed all experts as well as the expert consensus.
– Servan-Schreiber, E. J., Wolfers, J., Pennock, D. M. &amp- Galebach, B. (2004). Prediction Markets: Does Money Matter? Electronic Markets, 14, 243-251. [full text]
– For predicting the results of NFL games, Servan-Schreiber et al. (2004) compared the forecasts of two markets to those of 1,947 self-selected individuals. At the end of the season, the markets ranked 6th and 8th compared to the individuals. The human average – which would be the outcome of a classical survey – ranked 39th.

Markets vs. other forecasting methods

– Chen, K. Y., Plott, C. R. (2002). Information Aggregation Mechanisms: Concept, Design and Implementation for a Sales Forecasting Problem, Social Science Working Paper No.1131, California Institute of Technology, Pasadena. [full text]
– For forecasting sales figures, Chen and Plott (2002) reported on an internal market at Hewlett-Packard that beat the official forecasts of the company in 6 out of 8 events.
– Jones Jr., R. J. (2008). The state of presidential election forecasting – The 2004 experience, International Journal of Forecasting, 24, 308-319. [Abstract]
– Jones (2008) analyzed the forecasts of IEM&#8217-s vote-share market for the 2004 election and compared them to traditional polls, a Delphi expert survey, regression models and a combination of all four approaches, the Pollyvote. He concludes that in comparison with most methods of forecasting the popular vote, the IEM was the superior performer.Spann, M. &amp- Skiera, B. (2003). Internet-based Virtual Stock Markets for Business Forecasting, Management Science, 49, 1310-1326. [Full text]
– Spann and Skiera (2003) compared forecast accuracy of an internal market at a large German mobile phone operator. They found that the market forecasts outperformed were more accurate than four extrapolation models (arithmetic mean, geometric mean, linear trend and exponential trend).

Corporate Markets

– Chen, K.-Y. &amp- Plott, C. R. (2002). Information Aggregation Mechanisms: Concept, Design and Implementation for a Sales Forecasting Problem. Social Science Working Paper No.1131, California Institute of Technology, Pasadena. [Full text]
– Cowgill, B., Wolfers, J. &amp- Zitzewitz, E. (2008). Using prediction markets to Track Information Flows: Evidence from Google, working paper. [Full text]
– Ortner, G. (1997). Forecasting Markets – An Industrial Application: Part I, working paper, TU Vienna. [Full text]
– Spann, M. &amp- Skiera, B. (2003). Internet-based Virtual Stock Markets for Business Forecasting, Management Science, 49, 1310-1326. [Full text]

Decision Markets

– Hanson, R. (1999). Decision Markets, IEEE Intelligent Systems, 14, 16-19.

Manipulation

– [Except] Hansen et al. (1998), most empirical studies report that manipulative attacks on result accuracy have not been successful historically (Rhode and Strumpf 2006), in the laboratory (Hanson et al. 2006), and in the field (Camerer 1998).
– Camerer, C. (1998): Can Asset Markets Be Manipulated? A Field Experiment with Racetrack Betting, Journal of Political Economy, 106(3), 457-482. [Abstract]
– Hansen, J., Schmidt, C. &amp- Strobel, M. (2004). Manipulation in Political Stock Markets – Preconditions and Evidence, Applied Economics Letters, 11, 459-463. [Abstract]
– Hanson, R., Oprea, R. &amp- Porter, D. (2006). Information Aggregation and Manipulation in an Experimental Market, Journal of Economic Behavior &amp- Organization, 60, 449-459. [full text]
– Rhode, P. W., and Strumpf, K. S. (2006). Manipulating Political Stock Markets: A Field Experiment and a Century of Observational Data, Working Paper, University of North Carolina(2006). [full text]

–

More research papers on prediction markets

–

Is Big Brother being fixed in Great Britain? And are the alleged fixers using BetFair to make a fast buck (or quid, as they say in the U.K.)?

Posted on by
2

No Gravatar

Via Ed, The Daily Mail:

The Daily Star reveals that some punters are set to earn more than half a million pounds after a total bet of ?971 was staked via BetFair on Nikki to win at 1000-1 shortly after she was voted out of the house. […]

Rumours of &#8216-insider dealing&#8217- on BetFair chat forums continue to surround the clued up gamblers who stand to win ?582,250. […]

–

That &#8220-Nikki&#8221- was evicted, an later on re-instated in the game.

Hence, the questions about the traders who did bet on her, after her eviction. Did they &#8220-know&#8221- something that the other traders didn&#8217-t?

On the other hand, it&#8217-s a constitutional right for Joe A. Doe to bet ?971 on a loser. Many do that every day at the horse race track. We should not accuse people of insider trading (or corruption) without any evidence.

BetFair employs many specialists in their &#8220-integrity team&#8221- to deal with such occurrences.

–

CFTC regulation and election contracts

Posted on by
4

No Gravatar

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

Robust, the prediction markets are the best mechanism for aggregating information. Thus, companies should use them for assessing strategy and hedging risks.

Posted on by
5

No Gravatar

Via Emile Servan-Schreiber of NewsFutures, John Auters in the Financial Times.

[…] This leads to [Justin Wolfers]&#8216- claim that [prediction markets] are the best way to aggregate information. This is true of any given amount of information. Take three economists and make them trade out a market over their predictions for next month&#8217-s inflation number, he suggests, and they will arrive at a more accurate prediction than a poll of the same three economists. In a market, those with stronger conviction (or inside information) can express that conviction- those less confident will not be willing to stake money. […]

Prediction markets remain subject to the same weaknesses as other markets. The principle of &#8220-garbage in, garbage out&#8221- [*] applies. If there is only poor information to aggregate, they will be as wrong as everyone else. […]

It would make sense to incorporate these odds when making investments. […]

–

Excellent.

(I don&#8217-t get his micro slam against the wisdom of crowds. Anyway.)

–

[*] As explained in the prediction market explainer published on the frontpage of Midas Oracle.

–

ABC 20/20 – A good (but servile) explainer on the wisdom of crowds and the prediction markets

Posted on by
3

No Gravatar

ABC 20/20 featuring InTrade – (May 9, 2008)

Foretelling The Future: Online Prediction Markets &#8212- (4 pages in all)

ABC video

YouTube video

–

  1. Not a single word about InTrade-TradeSports fucking up its traders during the North Korea Missile episode.
  2. Although James Surowiecki is a great thinker overall, I&#8217-m not happy he served InTrade&#8217-s past forecasting successes in absolute terms &#8212-and not in terms of probabilities. That shows James Surowiecki can&#8217-t be the ultimate leader of the field of prediction markets. Robin Hanson, Justin Wolfers, Koleman Strumpf, Eric Zitzewitz, or even Emile Servan-Schreiber, would have not made that mistake.
  3. All prediction markets are not created equal. Spot that they go too far, saying terrorism prediction markets or earthquake prediction markets could serve a societal purpose. That is complete bullshit. That is pure hype. As I said yesterday, an analyst should check whether a given prediction market is really able of aggregating important information. Just because John Delaney wants to create a betting market to get money doesn&#8217-t mean that that given prediction market will be able to give sound forecasts. Otherwise, we would have prediction markets about future lottery outcomes and we would make a fortune out of that. :-D
  4. Spot that they put the emphasis on the easy translation between the 0&#8211-100 prices and the 0&#8211-100 probabilities. That puts BetFair&#8217-s model (based on those damn digital/decimal odds) out of the picture.

–

Ask anybody who suffered the recent bloodletting at HedgeStreet: CFTC regulation can impose crushing burdens. It has nearly driven that innovative business into the ground.

Posted on by
3

No Gravatar

That was Tom W. Bell, of course. And 5 months after Tom W. Bell&#8217-s pronouncement, HedgeStreet v1 ate the bullet and bellied up.

–

–

Doctor Pennock, isn&#8217-t &#8220-pragmatism&#8221- to take into perspective the hard facts povided by:

  1. the bankruptcy of the CFTC-regulated HedgeStreet v1,
  2. and the insolent health of the UK Gambling Commission-regulated BetFair?

Shouldn&#8217-t the &#8220-pragmatists&#8221- draw lessons from all that?

Or will the the &#8220-pragmatists&#8221- ignore the hard facts?

Of, yeah, please, let&#8217-s display &#8220-pragmatism&#8221-.

Back in your court, doc.

–

–

Here&#8217-s Tom W. Bell&#8217-s old take that prediction markets fall outside of the CFTC&#8217-s jurisdiction.

–

Folks, yesterday, I forgot to link to the PDF file posted by the CFTC (their concept release, how snobbish). Download it, and read it -well discuss it later, here. No need to rush an opinion, we have about 2 months to make up our collective mind. Lets have it open.

Posted on by
Reply

No Gravatar

Via professor Eric Zitzewitz of Dartmouth, the CFTC announcement.

–

CFTC&#8217-s Concept Release – (PDF file)

–

InTrade&#8217-s John Delaney&#8217-s message to the prediction market crowd.

–

Midas Oracle authors (and that includes PMIA&#8217-s Emile Servan-Schreiber) can post their views, here, if they wish &#8212-or link externally to their own blog, if they wish.

–

David Pennock has published a comment that rebuts mine.

–

One comment, over there.

–

Finally, I&#8217-m searching for a co-author, or a bunch of co-authors, who share my views, and would like to submit a short e-mail to the CFTC, before the end of June, 2008.

–

CFTC Requests Public Input on Possible Regulation of “Event Contracts” -a.k.a. event derivative markets, event futures markets, betting markets, bet markets, prediction markets

Posted on by
Reply

No Gravatar

Via professor Eric Zitzewitz of Dartmouth (one of the top 5 economists studying prediction markets), the CFTC:

Release: 5493-08
For Release: May 1, 2008

CFTC Requests Public Input on Possible Regulation of “Event Contracts”

Washington, DC – The Commodity Futures Trading Commission (CFTC) is asking for public comment on the appropriate regulatory treatment of financial agreements offered by markets commonly referred to as event, prediction, or information markets.

During the past several years, the CFTC has received numerous requests for guidance involving the trading of event contracts. These contracts typically involve financial agreements that are linked to events or measurable outcomes and often serve as information collection vehicles. The contracts are based on a broad spectrum of events, such as the results of presidential elections, world population levels, or economic measures.

“Event markets are rapidly evolving, and growing, presenting a host of difficult policy and legal questions including: What public purpose is served in the oversight of these markets and what differentiates these markets from pure gambling outside the CFTC’s jurisdiction?” said CFTC Acting chairman Walt Lukken. “The CFTC is evaluating how these markets should be regulated with the proper protections in place and I encourage members of the public to provide their views.”

In response to requests for guidance, and to promote regulatory certainty, the CFTC has commenced a comprehensive review of the Commodity Exchange Act’s applicability to event contracts and markets. The CFTC is issuing a Concept Release to solicit the expertise and opinions of all interested parties, including CFTC registrants, legal practitioners, economists, state and federal regulatory authorities, academics, and event market participants.

The Concept Release will be published in the Federal Register shortly- comments will be accepted for 60 days after publication in the Federal Register.

Comments may also be submitted electronically to [email protected]. All comments received will be posted on the CFTC’s website.

–

WOW.

–

UPDATE: Eric Zitzewitz tells me that comments are sought 60 days after publication in the Federal Register. So, the deadline for commenting will be somewhat around June 30, 2008.

–