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CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

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101–110 of 200 posts

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#101

“This action sends the important message that if you engage in manipulative and deceptive trade practices you will be caught, punished, and forced to give up your ill-gotten gains,” added Division of Enforcement Director James McDonald. No, Mr McDonald, it's quite the opposite. The important message is that if your organization can keep the profits from criminal activities higher than the penalties, they can perpetua…

US prosecutors literally said that they cannot criminally charge JPM (in another case) because that would destabilize the US financial system. They are literally "too big to jail".

The Chickenshit Club everyone

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#102
post #51

“This action sends the important message that if you engage in manipulative and deceptive trade practices you will be caught, punished, and forced to give up your ill-gotten gains,” added Division of Enforcement Director James McDonald. No, Mr McDonald, it's quite the opposite. The important message is that if your organization can keep the profits from criminal activities higher than the penalties, they can perpetua…

It’s crazy. If one tried to steal 10k from the bank, you would go to jail. If you steal millions through illegal trade practices, you just pay a fraction of what you stole.

Its not very different from the Flash crash, in 2015 an independent trainer named Navinder Singh Sarao was sued for manipulating the market, he was creating a lot of orders and cancelling them tricking the flash trading computers to push up the prices, he made around 45 million in the process while living in his parent house. In 2020 he was convicted with a year of confinement at home, no jail time, and a trading ban.

So yeah also not the biggest punishment, but more then what these bankers got, they are still allowed to trade and no confinement.

Whether he was the only one to do it and whether he was the main cause of crash is not clear, but at least he had a part.

I personally feel like if you allow flash trading to have such an advantage over investors without those means it shouldn't be illegal to exploit it, but anyway.

https://en.wikipedia.org/wiki/2010_flash_crash

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#103
post #63
post #51

Earlier quoted context omitted.

It’s crazy. If one tried to steal 10k from the bank, you would go to jail. If you steal millions through illegal trade practices, you just pay a fraction of what you stole.

Even if they had exactly the same outcome, one is theft the other is simply breaking the rules. It's a bit like killing a person using a gun and killing a person as a result of driving like the rules don't apply to you. Once it is established that you did the act, the first one undoubtedly puts you in jail for a very long time no matter who you are and the second one may get you a fine and no jail time so that no har…

Reminds me of my time at google.

There was a lesson in the new employee training on sexual harassment (for sales people, but still a general lesson) - don't bring a client to a strip club. A higher up sales manager had actually done this in the london office and it was posted on memegen, and mentioned that this was literally in the employee manual. Lesson: be a manager.

Lesson: be a bank. The more corrupt, the better (HSBC). Until another Hitler comes along and does something about it.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#104
post #53

Earlier quoted context omitted.

I often wonder: wouldn't fines paid as a percentage of stock be a better deterrent? Taking stock off shareholders changes the fraud equation from risk of fine vs the profitability upside, to shareholder's losing real value. That's the role of shareholders AFAICT, to hold their board and the company accountable. Fail to do so and lose your shareholding seems the right direct risk. The fines could also be a lot larger,…

Shareholders can't be asked to police the company. That's not their job. They don't have the resources nor the expertise to do it.

All you need is a few activist hedge funds to do the policing. You can’t blanket say that shareholders lack resources.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#105

“This action sends the important message that if you engage in manipulative and deceptive trade practices you will be caught, punished, and forced to give up your ill-gotten gains,” added Division of Enforcement Director James McDonald. No, Mr McDonald, it's quite the opposite. The important message is that if your organization can keep the profits from criminal activities higher than the penalties, they can perpetua…

US prosecutors literally said that they cannot criminally charge JPM (in another case) because that would destabilize the US financial system. They are literally "too big to jail".

Can you cite a source of a US DOJ head saying the actual quote you claim they said .

I work in the industry and follow things like this and I haven't heard the US government saying they would like to charge JPM but they can't due to destabilizing the US financial system.

I'll even let you go back 5 years to find such a quote!! I don't think i've heard of this happening.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#106
post #22

Why do CFTC try to police this? For the money or optics? Orders far from the BBO are clearly irrelevant and those close to the BBO are not "free" for the spoofer given they have to bear the risk that the orders could be filled if the market moves. Effectively it means anyone cancelling an order has to worry that their action could be interpreted as "spoofing" - which will make market making more risky and expensive.…

The SEC regulates the exact same thing for US stocks. And nearly every other country / regulated exchange has similar rules. When you post an order to any exchange, you are doing so under the agreement that it is legitimate and that you actually want to be filled at that price. Obviously a participant’s desire desire to be filled at a specific price can change over time, so you’re allowed to cancel orders as well. Th…

Actually it was the SEC rules I had some exposure to but this was a few years ago and was communicated to us via the compliance dept. What I recall is that because of the difficulty in proving intent, the rules allow very broad interpretation on the part of the SEC. The bar for proving spoofing seemed very low as, for example, the SEC does NOT have to demonstrate that you made a profit from it.

> But if the BBO isn’t really moving

That might looks suspicious sure, but there may be other factors (not reflected in the book) influencing a change of desire on my part. For example, what if I only want to buy one of GOOG or APPL and optimistically stick in a low-ball bid on each. If one gets filled, I cancel the other. I never intended for BOTH orders to be filled; is this spoofing? Or half-spoofing? This isn't a real strategy but there are lots of strategies which can look like this.

I agree the state of the order book drives a lot of the behavior of a strategy (but other factors like current position are also critical) but I've never come across a strategy that responds to volume changes far from the BBO. Not to say they don't exist - it's a secretive industry after all - but the changes at or very near the BBO clearly reflect real intent and are weighted accordingly. Quantity change far away from the action is mostly noise.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#107
post #30

Earlier quoted context omitted.

There were no "fake trades" involved in this case - only orders which were cancelled.

they were fined for 'spoofed' trades which in my view are fake trades - they never intended for them to execute, only to steer the market in a direction they want to fill in orders they had at a profit. if those trades ran the risk of executing they would have probably been cancelled fast and moved further.

The language of trading is fairly precise - trades and orders are quite distinct things. Orders may or (commonly) may not result in trades.

An order that doesn't execute is not associated with any trade.

JPMorgan were fined for spoofing orders not trades.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#108

Earlier quoted context omitted.

US prosecutors literally said that they cannot criminally charge JPM (in another case) because that would destabilize the US financial system. They are literally "too big to jail".

Can you cite a source of a US DOJ head saying the actual quote you claim they said . I work in the industry and follow things like this and I haven't heard the US government saying they would like to charge JPM but they can't due to destabilizing the US financial system. I'll even let you go back 5 years to find such a quote!! I don't think i've heard of this happening.

It's called the (Eric) Holder doctrine:

> That sentiment was echoed as late as 2012 by Lanny Breuer, then the head of the Justice Department’s criminal division, who said in a speech at the New York City Bar Association that he felt it was his duty to consider the health of the company, the industry, and the markets in deciding whether or not to file charges.

https://www.theatlantic.com/magazine/archive/2015/09/how-wal...

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#109
post #106

Earlier quoted context omitted.

The SEC regulates the exact same thing for US stocks. And nearly every other country / regulated exchange has similar rules. When you post an order to any exchange, you are doing so under the agreement that it is legitimate and that you actually want to be filled at that price. Obviously a participant’s desire desire to be filled at a specific price can change over time, so you’re allowed to cancel orders as well. Th…

Actually it was the SEC rules I had some exposure to but this was a few years ago and was communicated to us via the compliance dept. What I recall is that because of the difficulty in proving intent, the rules allow very broad interpretation on the part of the SEC. The bar for proving spoofing seemed very low as, for example, the SEC does NOT have to demonstrate that you made a profit from it. > But if the BBO isn’t…

> That might looks suspicious sure, but there may be other factors (not reflected in the book) influencing a change of desire on my part

I think your example would easily satisfy regulators. But you have to have the logging with real time stamps to prove it or you need to be able to reconstruct the internal state by replaying the market data against that version of the code.

Same goes for other pairs trades or other non-book signals. For any automated trading on regulated exchanges, you need to be able to explain to regulators why you chose to send an order. Otherwise you’re basically admitting that you don’t understand / have control over your algorithm, which they will obviously object to.

> I've never come across a strategy that responds to volume changes far from the BBO.

I agree it’s unlikely that a deep quote will provoke an immediate action. But sustained changes in the book will over time get aggregated into moving averages etc and influence behaviors in the long term (for whatever timescale may be appropriate).

> Quantity change far away from the action is mostly noise.

I agree that individual quotes are noisy, and it’s hard to extract signal from the noise. A limit order book by definition is supposed to quantify an aggregated demand to buy/sell, and thus it should be meaningful to aggregate over it to construct a distribution. Spoofing distorts that.

No one gets investigated for spoofing for sending a single order. It’s a persistent pattern that stands out from the noise.

Re: CFTC Orders JPMorgan to Pay Record $920M for Spoofing and Manipulation (2020)

#110

Earlier quoted context omitted.

Can you cite a source of a US DOJ head saying the actual quote you claim they said . I work in the industry and follow things like this and I haven't heard the US government saying they would like to charge JPM but they can't due to destabilizing the US financial system. I'll even let you go back 5 years to find such a quote!! I don't think i've heard of this happening.

It's called the (Eric) Holder doctrine: > That sentiment was echoed as late as 2012 by Lanny Breuer, then the head of the Justice Department’s criminal division, who said in a speech at the New York City Bar Association that he felt it was his duty to consider the health of the company, the industry, and the markets in deciding whether or not to file charges. https://www.theatlantic.com/magazine/archive/2015/09/how-w…

Here is the 2012 speech from Lanny Breuer [1].

And here is the 1999 memo from (then Deputy Attorney General) Eric Holder [2 PDF].

[1] https://www.justice.gov/opa/speech/assistant-attorney-genera...

[2] https://www.justice.gov/sites/default/files/criminal-fraud/l...

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