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Alsadius comments on [LINK] Bets do not (necessarily) reveal beliefs - Less Wrong Discussion
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Would you have had to disclose a put option position, or a credit default swap?
I never actually read the details of the disclosure requirements, but it would be strange to demand disclosures of stock but not of options, especially as the later would be more useful to someone seeking to do intersider trading (hence why spreads are, ceteris paribus, wider in options markets), while stocks are more conducive to a long term buy-and-hold strategy.
They vary a lot, so I've never bothered looking into the specific rules around it. I suspect you're right, of course(though CDS bets may be a viable loophole), but I figured it was a question worth asking.