IntelIP · hudsonaikins · Sep 10, 2026 · Sep 10, 2026 · Sep 10, 2026
diff --git a/docs/research/2026-09-10-venue-access-and-cost-plan.mdx b/docs/research/2026-09-10-venue-access-and-cost-plan.mdx
@@ -7,36 +7,45 @@ description: NRCL-101 vendor access questions, recording rights, and a bounded s
 
 Question: Which access model and data rights support a bounded sports recording pilot, and what evidence can justify the next execution venue?
 
-Prepared September 10, 2026. **Preparation complete; commercial permissions and comparative execution-cost study remain incomplete.** Reuses the September 9 venue brief. Delivered: vendor question drafts, access assessment, cost protocol and source references. No external messages, credentials, paid calls, orders or product-code changes. No contemporaneous matched-book study was run: settlement compatibility and recording/replay permissions are not established.
+Prepared September 10, 2026; access and fee sources refreshed later the same day. **Preparation complete; commercial permissions and comparative execution-cost study remain incomplete.** Reuses the September 9 venue brief. Delivered: vendor question drafts, access assessment, cost protocol and source references. No external messages, credentials, paid calls, orders or product-code changes. No contemporaneous matched-book study was run: settlement compatibility and recording/replay permissions are not established.
 
 ## Conclusion and decision informed
 
-Keep **Polymarket US as the provisional next data/paper integration** on technical readiness. Do not choose a live execution venue yet. Novig remains a serious sports candidate. Its public activity and fee schedule justify obtaining exact access terms; they do not establish hosted-use rights or better execution.
+Keep **Polymarket US as the provisional next data/paper integration** on technical readiness. **DEFER retained cross-venue product replay and cost ranking until written terms permit the intended combined/normalized data use.** Do not choose a live execution venue yet. Account access is distinct from permission to retain, transform or redistribute data. Novig remains a sports candidate; its access eligibility and recording rights remain unconfirmed. The operator explicitly deferred the real-data pilot. MLB remains a research sample; no sport or game is committed.
 
 Current blockers to the cost study:
 
 1. Exact listed contract pairs with sufficient settlement coverage. Kalshi and Polymarket US sampled MLB rules already differ on postponement; Novig has additional forfeit and timing differences. Similar propositions can be displayed with differences, but cannot enter the strict equivalent-contract cost ranking.
 2. Written recording, retention, replay and derived-display permissions for the intended local/cloud use, or an applicable published grant. None found for our full requested use.
 3. Suitable Novig read-only access to event identities and contemporaneous depth, including data/recovery permissions.
-4. Effective Kalshi series fee policy: current API and linked schedule conflict, described below.
+4. Kalshi fee rounding, match-fragmentation treatment and any account/program exceptions. The dated August multiplier change now explains the older PDF discrepancy; it is not an unresolved multiplier conflict.
 
 ## Confirmed facts: access and rights
 
 | Route | Confirmed | Unconfirmed for Neural/Vaticor |
 |---|---|---|
-| Polymarket US personal account | Retail app exposes API key creation; authenticated trading/portfolio/WebSocket API exists; public market-data gateway needs no key | Hosting a customer's key, unattended strategies, connection to existing accounts, read-only scopes, and storage/replay rights |
-| Polymarket US ISV | Firm authenticates and acts for onboarded retail participants; signed agreements, RSA/JWT credentials, preproduction test funds; documented flow includes KYC and funding integration | Whether a small software-only provider may link existing accounts without replacing onboarding/funding; automated-strategy permission; commercial cost and precise responsibilities |
-| Polymarket US institutional data | Market Data Agreement and requested `read:marketdata`, `read:l2marketdata`, `read:instruments` scopes | Retention limits, local/cloud replay, raw export, derived analytics, backups and post-termination deletion terms; agreement text not publicly retrieved |
+| Kalshi ordinary API | Developer Agreement permits storage for the member's own trading; prohibits other-member trading facilitation and benchmarking uses | Separate permission covering product replay, combined-data comparisons, hosted delegation and redistribution |
+| Polymarket US personal account | Retail app exposes API key creation; authenticated trading/portfolio/WebSocket API exists; public market-data gateway needs no key | Approved delegation for existing accounts, unattended strategies, read-only scopes and commercial storage/replay rights; the individual agreement prohibits credential sharing |
+| Polymarket US ISV | Firm acts for onboarded retail participants; public ISV agreement template grants conditional recording/distribution rights but restricts combining and modifying data | Executed terms permitting cross-venue normalization/replay; existing-account linking, unattended strategies, commercial cost and responsibilities |
+| Polymarket US institutional data | Market Data Agreement and read-only scopes; data guide recommends local historical-data storage for analysis | Retention limits, local/cloud replay, raw export, derived analytics, backups and post-termination deletion terms; agreement text not publicly retrieved |
 | Novig NBX | Client ID/secret requested from Novig; OAuth tokens; QA environment | Eligibility for personal read-only access versus market-maker access; third-party hosting, customer delegation, credential scopes and read-only depth entitlement |
 | Novig public/affiliate data | Public daily CSV downloads; affiliate documentation describes odds display and deeplinks | Whether CSV publication grants storage/replay/derivative rights; whether affiliate terms cover research and paper trading; hosted order routing |
 
 Sources: [Polymarket US authentication](https://docs.polymarket.us/api-reference/authentication), [ISV](https://docs.polymarket.us/partners/partner-types/isvs), [partner responsibilities](https://docs.polymarket.us/partners/your-role), [partner onboarding](https://docs.polymarket.us/partners/get-connected/onboarding), [data agreement route](https://docs.polymarket.us/data-guide/onboarding), [Novig authentication](https://docs.novig.com/api-reference/authentication), [Novig CSV schema](https://docs.novig.com/api-reference/trade-data), [Novig affiliates](https://docs.novig.com/affiliates/overview).
 
+**Kalshi published constraints:** Developer Agreement v1.1 sections 3/3.1 restrict API use and storage to the member's own trading; 3.2 bars facilitating other members' trading and 3.5 bars benchmarking/competitive uses. Sharing needs written approval. The separate website Data Terms exclude software development and providing cached datasets from personal noncommercial use. These sources do not establish a product-replay license. [Developer Agreement](https://assets.kalshi.com/Kalshi-Developer-Agreement.pdf), [website Data Terms](https://kalshi-public-docs.s3.amazonaws.com/kalshi-data-terms-of-service.pdf).
+
 **Current agreement constraints:** Novig Member Agreement v1.1, sections 5.4.1/5.4.4, requires personal or entity-authorized access and bars controlling another member's account or sharing access materials. Section 11.1 requires express written consent to reproduce, retransmit or distribute price/trading information and derivatives. This is not evidence that every API program uses identical terms; it prevents treating a member login or public CSV as a sufficient hosted/replay license. [Current Novig agreement](https://support.novig.com/en/articles/16075495-ludlow-exchange-llc-member-agreement)
 
-The **current downloaded** Polymarket US Entity Participant and Clearing Member Agreement, I.24, restricts redistribution unless expressly permitted; I.26 prohibits making login credentials available to another person/entity. This is an entity-participant agreement, not the unavailable ISV/data agreement or proof of retail-account scope. A stale search excerpt at the same URL describes older, broader “API Materials” restrictions; use the downloaded document, not that excerpt. General retail TOS page returned no readable body in this environment. [Current entity agreement](https://www.polymarketexchange.com/files/legal/latest/participant-agreement-corporate)
+The **current downloaded** Polymarket US Entity Participant and Clearing Member Agreement, I.24, restricts redistribution unless expressly permitted; I.26 prohibits making login credentials available to another person/entity. This is an entity-participant agreement, not the separate ISV or Market Data Agreement. A stale search excerpt at the same URL describes older, broader “API Materials” restrictions; use the downloaded document, not that excerpt. The current Individual Participant Agreement v1.4 (August 6, 2026) requires written production-API approval in I.19, restricts redistribution in I.22 and prohibits credential sharing in I.24. General retail TOS still returned no readable body. [Entity agreement](https://www.polymarketexchange.com/files/legal/latest/participant-agreement-corporate), [individual agreement](https://www.polymarketexchange.com/files/legal/latest/participant-agreement).
+
+The publicly linked **ISV Connectivity Agreement v1.4 (August 27, 2026)** is an unsigned template. Section 2.4 grants licensed vendors recording and distribution of full-depth data to their Users through Vendor Software, but requires unchanged data and prohibits combining it with other data. It permits deidentified aggregate reporting/marketing statistics that cannot disclose or reconstruct raw data. Sections 9.5–9.6 require cessation and return/destruction after termination, subject to restricted compliance retention; relevant User activity/audit trails must be kept five years or longer where required. This is not a grant to Neural/Vaticor or a cross-venue replay permission. [ISV agreement, linked by official documentation](https://drive.google.com/uc?export=download&id=1cKsp4HrXEfU6_tduZxojXlbrB008YsB9), [official ISV page](https://docs.polymarket.us/partners/partner-types/isvs).
+
+The Polymarket US data guide recommends storing historical data locally for analysis, while onboarding requires a Market Data Agreement. This supports a possible licensed local-analysis route; it does not specify our retention period, cloud replay or combined-data rights. [Data handling](https://docs.polymarket.us/data-guide/market-data), [data onboarding](https://docs.polymarket.us/data-guide/onboarding).
 
-API reachability supports technical feasibility. **Retention/replay permission remains unconfirmed.** Continue offline synthetic-fixture engineering; hold new retained venue recording datasets and customer-facing data redistribution until applicable terms answer the questions below. This is a scoped research decision, not a legal opinion on every personal API use.
+Novig documents authenticated order-level books: market-specific subscriptions receive initial snapshots; the global tape does not. Quantity is in Minimum Currency Units, and market closure requires a separate lifecycle channel. The word public describes the data channel, not anonymous access: OAuth JWT authentication remains required. Eligibility, commercial terms and retention rights still need confirmation. [Order book channel](https://docs.novig.com/api-reference/WSS/orderbook-channel), [WebSocket authentication](https://docs.novig.com/api-reference/WSS/authentication).
+
+API reachability supports technical feasibility. **Permission for retained cross-venue product replay remains unconfirmed.** Continue offline synthetic-fixture engineering; hold new retained venue recording datasets and customer-facing data redistribution until applicable terms answer the questions below. This is a scoped research decision, not a legal opinion on every personal API use.
 
 ## Questions ready to send
 
@@ -49,7 +58,7 @@ Subject: Neural/Vaticor — MLB replay rights and effective series fee policy
 We build Neural, an SDK for sports-market normalization and paper strategy replay, and Vaticor, its hosted user workflow. Initial scope is a read-only MLB pregame full-game winner study with no live orders.
 
 1. Which current agreement permits three games and nine paired snapshot times in one day, 30-day raw book/metadata retention for local and cloud replay, and 90-day derived comparison results? Please specify customer display, raw export, backups, deletion and cross-venue comparison rights. These periods are proposed requests, not assumed grants.
-2. For `KXMLBGAME`, which effective maker/taker coefficients and multipliers govern the study account? The series API reports `quadratic_with_maker_fees` and multiplier `0.5`, while the linked July 7 schedule lists maker/taker multipliers `1/1`. Please identify the controlling dated source and account or program exceptions.
+2. The fee-change endpoint records `KXMLBGAME` multiplier `0.5` from August 7, 2026, after the July 7 PDF. Please confirm applicable maker/taker coefficients and any study-account or program exceptions; the dated multiplier change itself is established.
 3. Please confirm rounding units, cumulative versus per-fill calculation, and how split matches affect fees. Does the fee-plus-position-cost rule round to a centicent, and what explains the schedule's cent-rounded examples? Is a supported fee preview available without submitting an order?
 4. Which access model supports customer-owned existing accounts, hosted read-only data and later user-configured unattended strategies? Please identify delegation, key custody, geography, data scopes and commercial requirements separately. We are not requesting permission to trade in this initial pilot.
 
@@ -64,7 +73,7 @@ We build Neural, an SDK for sports-market normalization and paper strategy repla
 1. Can customers use their existing Polymarket US accounts through our software, locally and later hosted, or must we onboard them through the ISV firm model? Does the answer differ for read-only data and user-configured unattended strategies?
 2. Which agreement and scopes permit a bounded internal trial: three games, nine snapshot times in one day, book/market metadata retained for 30 days, local and cloud replay, and derived comparison results retained for 90 days? Please specify raw-data export, customer display, backups and deletion obligations; proposed periods are requests, not assumed grants.
 3. Can an ISV link existing accounts without operating the documented partner funding flow? What delegation, key custody, user consent, geography checks and commercial charges apply?
-4. Please provide current ISV and Market Data Agreements, approved read-only access route, and current effective quantity/fee rounding rules. Are any additional permissions required for synthetic paper fills and cross-venue comparisons?
+4. Please provide the applicable Market Data Agreement and confirm the approved read-only route. Can written terms expressly permit cross-venue normalization, combined-data comparisons and paper replay despite ISV Connectivity Agreement 2.4? Please distinguish the proposed dataset retention from User audit-trail retention under 9.6, and confirm quantity/fee rounding.
 
 ### Novig
 
@@ -97,9 +106,9 @@ We build Neural, an SDK for sports-market normalization and paper strategy repla
 
 **Predeclared venue decision:** a cost-based preference requires at least six qualified paired sets spanning two games at each requested size, and the same venue must have a strictly lower total-cost interval in every qualified comparison across all three sizes. Any reversal, tie or overlapping interval among otherwise eligible observations means defer; missing the coverage threshold at any size also means defer. Do not change size weights, omit unfavorable qualified snapshots or choose a different primary size after seeing results. Account permissions and usable data remain prerequisites. If this rule defers, the provisional technical-readiness recommendation remains separate from cost evidence. A passing one-day pilot supports only the next bounded adapter decision, not persistent venue superiority.
 
-## Conflicts and unknowns: fees before ranking
+## Effective fees and remaining precision unknowns
 
-Live Kalshi `KXMLBGAME` series returns `fee_type=quadratic_with_maker_fees` and `fee_multiplier=0.5`. The linked July 7 fee PDF lists KXMLBGAME maker/taker multipliers 1/1. It describes fee-plus-position-cost rounding to a centicent while its illustrative table uses cents. Do not silently choose a value or use the earlier generic $1.75 comparison as the current MLB fee. Confirm the effective series/account policy or obtain a venue-supported preview. [Live series](https://api.elections.kalshi.com/trade-api/v2/series/KXMLBGAME), [fee schedule](https://kalshi.com/docs/kalshi-fee-schedule.pdf)
+Kalshi `KXMLBGAME` currently reports `quadratic_with_maker_fees` and multiplier `0.5`. The historical fee-change endpoint records multiplier `1` from October 4, 2025, then `0.5` at **2026-08-07T04:59:45.131Z**, change ID `38032af2-e3fa-4659-9280-da64300b544c`. This later change explains the July 7 PDF's `1/1` row. Use the dated series policy when preparing estimates; do not retain the superseded multiplier discrepancy as a current blocker. Rounding remains unresolved: the PDF says fee-plus-position-cost rounds to a centicent, while examples use cents. Confirm account exceptions and split-match rounding or obtain a supported preview before exact cost ranking. No fee preview or orders were submitted. [Live series](https://api.elections.kalshi.com/trade-api/v2/series/KXMLBGAME), [dated fee changes](https://api.elections.kalshi.com/trade-api/v2/series/fee_changes?series_ticker=KXMLBGAME&show_historical=true), [endpoint documentation](https://docs.kalshi.com/api-reference/exchange/get-series-fee-changes), [fee schedule](https://kalshi.com/docs/kalshi-fee-schedule.pdf)
 
 Polymarket US documents a 0.06 taker coefficient with banker's rounding and cumulative adjustment across fills; Novig straight-contract fees depend on event liveness at match time and use five-decimal ledger precision. Freeze effective policies in the trial instead of a generic cross-venue fee constant. [Polymarket US fees](https://docs.polymarket.us/fees), [Novig fees](https://docs.novig.com/fees)
 
@@ -122,3 +131,5 @@ The following digests identify retrieved source bytes, not semantic version guar
 The Novig digest identifies the 400,144-byte PDF retrieved through a signed attachment URL, not the contract-directory HTML. The link above preserves that exact attachment path while omitting temporary access parameters; it does not promise permanent unauthenticated access. Obtain a fresh attachment link from the [contract directory](https://support.novig.com/en/articles/16083642-contracts) if needed. The original capture metadata binds the signed PDF path, byte count, retrieval time and digest.
 
 Polymarket US current entity-agreement SHA256: c6975964cff6441cef9c4a699201c01efc1c14c42cef66eca72e9a19c70053a4. Downloaded September 10, 2026; latest URL is mutable. This supports the distinction from stale search-index text.
+
+Polymarket US ISV Connectivity Agreement v1.4 SHA-256: `0cab5c64584d855fe7914ac08be018404cbb3fd233493aef5ce255e38c151c41`. Retrieved September 10, 2026 from the official ISV page's public download. This identifies the unsigned template, not an executed agreement.