CFTC

  • 17 May 2013 at 5:50 PM

Nobody’s Happy With CFTC’s Plan To Only Micromanage Swaps Trading Strategy A Little

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Are you as puzzled as I am by the mild brouhaha over the CFTC’s new swap execution facility rules? Basically the rules require that most swaps be traded on pseudo-exchange-y-type things called “swap execution facilities,” which are run either by an order-book system or a “request for quote” system. The RFQ system would require anyone wanting to trade to send an RFQ to at least 3 (2 for “an initial phase-in period”) potential counterparties. The original proposal was for that to be five counterparties. The revised proposal has caused a striking amount of rage, as various people have confused themselves into thinking that of course it’s obvious that every transaction should be an auction among five potential counterparties. Presumably few of those people orient their daily life that way. I don’t, anyway; I get lunch at Chipotle every day because it’s next door to Dealbreaker HQ.1

On the other hand people who think that customers should choose how many quotes to get don’t like the 3-quote compromise either. Here’s a SIFMA guy whining about it, and he doesn’t seem all that wrong:

SIFMA’s Asset Management Group continues to believe that any minimum-bid requirement will tie the hands of portfolio managers who already have a fiduciary obligation to serve the best interests of their clients. Requiring portfolio managers to broadcast their trading position more widely than they would otherwise choose could negatively impact the prevailing price of their trades, making it more expensive and difficult to hedge their clients’ risk. SIFMA strongly believes that professional investment managers, and not the government, should determine appropriate trading strategy.

The thing that trading is is, deciding how broadly to expose your order. Wider exposure gets you more and potentially better bids, but at the risk of getting front-run or picked off or otherwise abused.2 I realize that I won’t persuade everyone by quoting a trading textbook but here: Read more »

  • 01 May 2013 at 3:34 PM

Bart Chilton Can Solve CFTC Funding, High-Frequency Trading Problem In One Fell Swoop

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If Congress won’t act to curb derivatives speculation (and fund his own agency) with a transaction fee, Bart Chilton will. Read more »

  • 17 Apr 2013 at 6:25 PM

Bloomberg Wants Regulation To Be Fair And Consistent For Some Reason

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I confess that I have not followed the swap-futurization thing closely but my assumption was that the politico-regulatory view was:

  • Swaps are evil instruments of financial instability and fraud and should be discouraged, and
  • Listed futures are mostly harmless.

I mean, look around. Swaps blew up AIG, Oakland, Monte dei Paschi, the U.S. housing market, whatever. Futures just blew up those old guys in Trading Places.

You can have various objections to this preference for futures,1 but surely the most compelling is that swaps and futures are to some reasonable approximation the same thing. They’re just delta-one exposures to some underlying quantity; calling them a “swap” or “future” doesn’t matter economically.

That, anyway, is Bloomberg’s line of argument: Read more »

  • 06 Mar 2013 at 2:59 PM
  • CFTC

You Will Have Gary Gensler to Kick Around (For a While)

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President Obama has decided that CFTC chief Gary Gensler, unlike most of his first-term economic team, is worth keeping around. Gary Gensler agrees. Now if only they could figure out in what capacity. Read more »

  • 22 Feb 2013 at 12:34 PM

CFTC Sues CME Customer Service Representatives For Providing Overly Enthusiastic Customer Service

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One thing that people like to say is that insider trading in commodities is just fine. It’s the point, even: the main people – if some politicians had their way, the only people – who trade in commodities are the people growing them, or digging them out of the ground, or whatever one does to make commodities on the one hand,1 and the people eating them or burning them or whatever one does with commodities on the other hand. All hedging real-world activity, no speculation. And if you’re a huge wheat grower, and all your wheat was involved in some sort of unexpected wheat accident, then you will probably want to go buy some wheat in the market (to close out your hedges or satisfy your contracted delivery requirements or bake your bread or whatever). And you’ll probably want to do that before prices go up when people realize that the supply of wheat is lower than expected. And you can do that. That’s fine. That’s hedging, more or less, not insider trading.

But that’s not the whole story. Trading in advance of your own inside information is okay, but trading in advance of someone else’s inside information is … sometimes problematic, depending on where you get that information from. For instance, operations people at commodities exchanges really shouldn’t be telling traders on those exchanges confidential information about other traders’ positions and trades. Like Billy Byrnes and Christopher Curtin allegedly did. It’s bad. Humongously bad even: Read more »

  • 13 Feb 2013 at 5:36 PM

CFTC Commissioner Bart Chilton’s Degree In Folklore And Mythology Proves Surprisingly Practical

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Finally, boys and girls, I want to tell you a bit about a children’s story. Once upon a time in a faraway land there lived a sweet young maid named Little Red Riding Hood—yeah, her. … Now, ye of little faith, before you think I’ve stopped carrying on your wayward son from futures, markets, Massive Passives and technology, hold your horses, or cheetahs or wolves of a color of your choice. Whatever they are, just hold ‘em a cotton-picking, or corn, bean or rice-picking minute! Maybe it is Minute Rice—I forget. The rice guys can help me out later. Read more »

  • 06 Feb 2013 at 1:34 PM

RBS’s Seating Arrangements Deprived The World Of Untold Embarrassing IM Conversations

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It’s getting to be a struggle to be amused by Libor manipulation chats. RBS took its lumps today, and the CFTC and FSA orders are full of quotes, and you can read them in various round-ups, but, meh. Even Bart Chilton is bored; today’s imagery (“sends a signal to those who would monkey around with benchmark rates … much more than a slap on the wrist …”) is a letdown after his UBS masterpiece (“Financial sector violations are hurtling toward us like a spaceship moving through the stars”) just a few weeks ago. I get it! Everyone manipulated Libor! In writing! And then they were like “heh, fukin awexome man, u manipluated libor, gud work, i sexx u now, w champain.” Fabulous.1

Part of why RBS provides less delight than its predecessor Libor-settlers is that RBS made use of the oldest and most reliable way to avoid typos: not typing. From the CFTC order: Read more »

  • 04 Jan 2013 at 6:24 PM

New Reporting Requirements Let You Watch Swaps Trading In Fake-Real-Time, If That Sounds Like Something You’d Like

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What should we do with the new real-time swaps data depository? As of the new year, the CFTC is requiring all swaps dealers to report their swaps trades in real time, starting with rates and credit index trades, and here is the data depository with those (anonymized) reports. It’s … not particularly real-time! It’s not particularly user-friendly either, I gotta say; somebody is presumably planning to make a lot of money translating these zip files of haphazardly coded data into Useful-ese.

But I guess we can pick at it now, no? What is interesting here? That sort of depends on what you want. If, like me, you’re into general bloviating, this seems like as good a source as any for a rough depiction of what trading activity in the credit index and rates derivatives markets looks like. So, for example, here is a delightful table of notional amounts traded yesterday across rates products and currencies; the notionals appear to be in local currency so one important takeaway is “boy a South Korean won is not worth a lot of money.” Or here is a toy chart I made by downloading the “cumulative slice report” for rates trades and focusing on US-dollar-only trades, then slicing them by what sort of rates they used1:

One conclusion to draw here is, remember when people were talking about phasing out Libor because it’s so corrupt and made-up and stuff? Read more »

  • 19 Dec 2012 at 3:50 PM
  • Banks

Sometimes UBS Traders Manipulated Libor Just To Mess With Each Other

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The last of the UBS Libor settlements to come out was the U.S. one and it has some of the best quotes. There’s the yen swaps trader who said “I live and die by these libors, even dream about them.” There’s … I mean, there is the life and career of Bart Chilton, in toto; here is a thing he said:

“A Conscience Isn’t Nonsense”

Statement of Commissioner Bart Chilton on UBS Settlement

December 19, 2012

Every so often, folks wonder if some in the financial sector believe that having a business conscience is nonsense. Financial sector violations are hurtling toward us like a spaceship moving through the stars. All too often, penalties have been a simple cost of doing business. That needs to change.

Particularly good are the exhibits to the criminal complaint against Tom Hayes and Roger Darin. We’ve previously met Hayes, cleverly disguised as Trader A; he was the senior yen swaps trader at UBS in Tokyo. Darin was the short-term rates trader “in Singapore, Tokyo, and Zurich,” though probably not all at once; he and his team submitted yen Libors for UBS. You can guess what happened when they got together!

But you don’t have to guess because there are lots of transcripts of their chats in the exhibits.1 Here is a problematic one: Read more »

  • 04 Dec 2012 at 10:02 AM

Study Suggests High Frequency Trading Might Cost Small Investors Almost One One-Hundredth Of One Percent Of Their Investments

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What do you think of the big HFT study? It’s this big HFT study that CFTC chief economist Andrei Kirilenko conducted on S&P 500 e-mini futures at the CME, and it’s already inspired a metaphor from CFTC commissioner and all-purpose spinner of metaphors Bart Chilton:

Mr. Chilton said that the study would make it easier for regulators “to put forth regulations in a streamlined fashion. It’s a key step in the process and it should fuel-inject the regulatory effort going forward.”

Not his best effort, fine. Anyway, the study: I’m not sure I’ve earned the right to have an opinion, both because (1) that, generally, and (2) my model of high frequency traders as micro-mini-market-makers is a bit upended by the fact that the bulk of the HFTs in this study seem to be taking, rather than providing, liquidity.1 It’s possible that the e-mini market is not the best place to measure the overall effects of HFT, either for fundamental reasons (its use for hedging etc.) or more crassly because it lacks the liquidity rebates that drive a lot of HFT in other markets.

That said what I like about this study is that instead of measuring transaction costs in naive ways like “bid/ask spread,” it measures transaction costs in sensible ways like “in a series of zero-sum transactions, how much money do HFTs suck out in profits.” Though the measure of profitability is sort of kooky:

The profits calculated in Table 3 are the implied short-term profits: we calculate the marked-to-market profits of each trader on 1 minute frequencies2 and reset the inventory position of each trader to zero after each of these 1 minute intervals. Then, we sum up all the 1 minute interval profits to get a measure of daily profits. Therefore, we capture the short-term profits of traders and not gains and losses from longer-term holdings.

What this means is that if your model of market-making is “buy at 99.9, wait five minutes, and sell at 100.1,” then your profits might end up showing as 0.2 or -0.2 or zero or something else on that calculation.3 So regular old market making may look bad, while HFT market making – designed to move quickly – looks much better. And so you get this table: Read more »

  • 27 Nov 2012 at 11:13 AM

Now You Can’t Buy Your Crude Oil Futures In $10 Increments On Intrade

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Like a lot of people I got an email yesterday telling me to close my Intrade account. This will not be a problem for me because:

Now I know it looks like I was terrible at predicting the election, but the real explanation is of course that I was astutely predicting the end of Intrade and managing my account to a level appropriate for that outcome. Though I assume there’ll be a $20 bank transfer fee to get those twenty cents out.

This CFTC suit is weird, huh? It’s effectively shut down Intrade for allowing US citizens to make illegal options trades, but its theory is a bit murky. One obvious thing about Intrade is that it is a little illegal to bet on U.S. elections and Oscar winners and all the other things you can bet on on Intrade, because it is a little illegal to bet on anything. This is America; you’re just not supposed to bet on things.

Except the things that the CFTC is willing to let you bet on.1 That’s a weird grab bag; you can bet on gold and orange juice and pork bellies and interest rates but not … well, not onions, but more relevantly, not elections. The CFTC is not a fan of election betting; earlier this year they rejected a request to allow trading of political event contracts on a derivatives exchange. And of course Intrade is for betting on elections, so of course the CFTC wants to shut them down.

Except that the CFTC isn’t suing Intrade for letting you bet on elections; it’s suing Intrade for letting you bet on the things that the CFTC lets you bet on. Go read the CFTC complaint; it doesn’t mention elections. The CFTC’s problems are with “binary options betting on the future prices of gold and crude oil, and changes in the U.S. unemployment rate and U.S. gross domestic product figures.” Which are just fine for betting on. Just not, it seems, on Intrade. Read more »