Security Market Manipulations and the Assurance of Market Integrity
By
Shan Ji
Supervisor: Professor Mike Aitken
Co-supervisor: Professor Frederick H. deB. Harris
This thesis is presented for the degree of Doctor of Philosophy in Finance At The University of New South Wales
Banking and Finance Australian School of Business 2009
Abstract
This dissertation is motivated by two major factors. First, there have been no direct studies conducted for the relationship between market integrity and market efficiency and the driving forces behind the cross-sectional variations in market quality. Second, a better understanding the relationships among market integrity, market efficiency and other mechanism design factors for securities exchanges will facilitate securities exchanges achieve a satisfactory level of market quality.
This dissertation consists of three chapters. In Chapter 1, a review of literature on market manipulation will be given. A series of common securities market manipulation strategies and corresponding market surveillance alerts will be explained and defined.
In Chapter 2, we develop a testable hypothesis that market manipulation as proxied by the incidence of ramping alerts would raise transaction cost for completing larger trades. We find ramping alert incidence positively related to effective spreads in 8 of 10 turnover deciles from most liquid to thinnest-trading securities. The magnitude of the increase in effective spreads when ramping manipulation incidence doubles is economically significant, 30 to 40 basis points in many moderate liquidity deciles. This compares with an average effective spread of 72 basis points for index-listed securities in the most efficient electronic markets worldwide.
In Chapter 3, In Chapter 3 of this thesis, we test the correlation between the levels of market integrity as proxied by the incidence of ramping alerts and a combination of proxies for factors from the following four potential drivers deciding the market quality across securities exchanges: • Securities Markets Trading Regulations • Securities Markets Technologies
• Securities Market Infrastructure • Securities Market Participants
The model we developed to test the correlation between the proxies for level of market integrity and seven proxies for the four potential drivers were estimated with Ordinary Least Square (OLS) and Two-stage Least Square (2SLS) error structures assumed, respectively to learn the most about the possible endogeneity of spreads and volatility. By performing Hausman-Wu specification tests, we concluded that simultaneity bias in the thickly-traded deciles is not material for the AI-Volatility and AI-Spread equation pairs. Subsequently, we used the PROBIT model to analyse the probability of adopting RTS across the 240 securities exchange deciles and the likelihood proves to be systematically related to four determinants in our sample. Finally we estimate the structural equations to investigate possible cross-equation correlation of the disturbances with either seemingly unrelated regression (SURL) estimation.
Our findings are three-fold. Firstly, in the moderately-traded deciles, we find that the presence of a closing auction (CloseAucDum) reduces the incidence of ramping alerts. Trade-based manipulation proves more difficult when a manipulator’s counterparties can use closing auctions to unwind their intraday exposures. The RTS dummy variable is significantly positively related to alert incidence. In the absence of any panel data on the dynamic effects of adopting RTS, what we are observing in cross section is the perceived vulnerability of certain exchanges to manipulation and their consequent adoption of RTS plus the regulatory regimes required to have a salutary effect on market integrity. Second, in the moderately-traded deciles, we find that the closing auctions and more regulations in pursuit of market integrity lower quoted spreads. RTS and a regulation specifically prohibiting ramping indicate in cross- section the perceived likelihood of more ramping. Thirdly, in terms of the probability of the deployment of a real-time surveillance system, the estimations again differ by liquidity decile grouping. In the moderately-traded deciles, higher alert incidence, the presence of DMA, and higher FDI again increase the likelihood of adopting a real- time surveillance system.
iii
Our findings have a couple of policy implications for many securities exchanges in terms of market design and market surveillance. First, the exhibited relationship between alert incidence and effective spreads indicates trade-based manipulation has a significant impact on execution costs. Therefore, the prevention of securities market manipulation not only serves the indirect purpose of improving an exchange’s reputation for market integrity but also contributes directly to achieving a more efficient marketplace. Second, our results indicate that some market design changes can enhance the regulatory efforts to prevent securities market manipulations. For example, to prevent manipulators from marking the closing price, some exchanges could choose to adopt a closing auction or a random closing time, which would make manipulation more costly. Nevertheless, no securities exchange can be designed perfectly. Consequently, exchange and broker-level surveillance backed by effective regulatory enforcement is a necessary and pivotal complement to good design choices.
iv
Table of Contents
ABSTRACT ...... II
TABLE OF CONTENTS ...... V
CERTIFICATION ...... VIII
ACKNOWLEDGEMENTS ...... IX
LIST OF DIAGRAMS ...... XI
LIST OF TABLES ...... XII
CHAPTER 1 ...... 1
MANIPULATION: A SURVEY AND LITERATURE REVIEW ...... 1 1.1 INTRODUCTION ...... 1 1.2 LITERATURE REVIEW ...... 4 1.2.1 THE EXISTENCE OF MANIPULATION IN SECURITIES MARKET ...... 5 1.2.2 THE FORMS OF SECURITIES MARKET MANIPULATION ...... 7 1.2.3 VOLATILITY, SPREAD AND SECURITIES MARKET MANIPULATIONS ...... 9 1.3 SECURITIES MARKET MANIPULATIONS ...... 12 1.3.1 RAMPING ...... 12 1.3.2 UNUSUAL EXPIRATION DAY ACTIVITY ...... 13 1.3.3 MISLEADING ORDER AND TRADING STRATEGIES ...... 13 1.3.4 WASH TRADES ...... 15 1.3.5 DERIVATIVE-UNDERLYING PRICE MANIPULATION ...... 15 1.3.6 LAYERING THE ORDERBOOK ...... 16 1.3.7 CHURNING ...... 17 1.3.8 CORNERING THE MARKET ...... 18 1.3.9 SQUEEZING THE MARKET ...... 19 1.3.10 FRONT RUNNING ...... 19 1.4 ALERTS FOR SECURITIES MARKET MANIPULATIONS ...... 21 1.4.1 INTRODUCTION ...... 21
v
1.4.2 THE MARKING THE CLOSE ALERT ...... 22 1.4.3 REVERSAL THE NEXT TRADING DAY ...... 23 1.4.4 THE BAIT AND SWITCH ALERT ...... 24 1.4.5 WASH TRADE ...... 24 1.4.6 DERIVATIVES/UNDERLYING PRICE MANIPULATION ...... 25 1.4.7 CORNERING THE MARKET ...... 26 1.4.8 SQUEEZING THE MARKET ...... 26 1.4.9 LAYERING THE ORDER BOOK ...... 27 1.4.10 CHURNING ...... 28 1.4.11 FRONT RUNNING ...... 29
CHAPTER 2 ...... 30
MARKET INTEGRITY AND MARKET EFFICIENCY: A CROSS-MARKET COMPARISON ...... 30 2.1 INTRODUCTION ...... 30 2.2 RESEARCH METHODOLOGY ...... 32 2.2.1 MARKET INTEGRITY DEFINED FOR THIS RESEARCH ...... 32 2.2.2 MARKET EFFICIENCY DEFINED FOR THE THIS RESEARCH ...... 34 2.2.3 RANDOM EFFECTS MODEL ...... 36 2.2.4 MODEL SPECIFICATIONS ...... 40 2.3 DATA AND MEASUREMENT ...... 42 2.3.1 DATA ...... 42 2.3.2 RAMPING ALERT INCIDENCE ...... 44 2.3.3 TIME-WEIGHTED QUOTED SPREAD AND VOLUME-WEIGHTED EFFECTIVE SPREAD ...... 47 2.3.4 DESCRIPTIVE STATISTICS ...... 49 2.3.5 LIMITATIONS OF RESEARCH DESIGN ...... 55 2.4 EMPIRICAL SPECIFICATION ...... 57 2.5 EMPIRICAL RESULTS ...... 59 2.5.1 ANNUAL AVERAGE DAILY QUOTED SPREAD FOR ALL DECILES ...... 59 2.5.2 ANNUAL AVERAGE DAILY QUOTED SPREADS (THICKLY-TRADED DECILES) ...... 62 2.5.3 ANNUAL AVERAGE DAILY QUOTED SPREADS (THINLY-TRADED DECILES) ...... 72 2.5.4 SUMMARY OF QUOTED SPREADS RESULTS ...... 82 2.5.5 ANNUAL AVERAGE DAILY EFFECTIVE SPREADS (ALL DECILES)...... 83 2.5.6 ANNUAL AVERAGE DAILY EFFECTIVE SPREADS (THICKLY-TRADED DECILES) ...... 85 2.5.7 ANNUAL AVERAGE DAILY EFFECTIVE SPREADS (THINLY-TRADED DECILES) ...... 95 2.5.8 SUMMARY OF RESULTS FOR EFFECTIVE SPREADS ...... 105 2.6 DISCUSSION OF RESULTS ...... 106 2.7 SUMMARY AND CONCLUSION ...... 108
CHAPTER 3 ...... 110
AN EMPIRICAL MODEL OF THE INCIDENCE OF SECURITIES MARKET MANIPULATION ...... 110 3.1 INTRODUCTION ...... 110 3.2 PRIOR LITERATURE ...... 113 vi
3.2.1 REGULATIONS ...... 113 3.2.2 INFORMATION ...... 114 3.2.3 TECHNOLOGY ...... 114 3.2.4 MARKET INFRASTRUCTURE ...... 116 3.2.5 PARTICIPANTS ...... 116 3.3 RESEARCH METHODOLOGY ...... 118 3.3.1 PROXY FOR MARKET INTEGRITY ...... 118 3.3.2 PROXIES FOR SECURITIES MARKET REGULATIONS ...... 118 3.3.3 PROXY FOR TECHNOLOGY ...... 119 3.3.4 PROXIES FOR SECURITIES MARKET INFRASTRUCTURE ...... 119 3.3.5 PROXIES FOR SECURITIES MARKET PARTICIPANTS ...... 120 3.3.6 MODEL SPECIFICATION ...... 121 3.4 DATA AND MEASUREMENT ...... 123 3.4.1 DATA ...... 123 3.4.2 RAMPING ALERT INCIDENCE ...... 125 3.4.3 TIME-WEIGHTED QUOTED SPREAD ...... 127 3.4.4 AVERAGE VOLATILITY ...... 128 3.4.5 AVERAGE LIQUIDITY ...... 128 3.4.6 DUMMY VARIABLES ...... 129 3.4.7 DESCRIPTIVE STATISTICS ...... 129 3.4.8 LIMITATIONS OF RESEARCH DESIGN ...... 131 3.5 EMPIRICAL SPECIFICATION ...... 132 3.6 POSSIBLE ENDOGENEITY OF ALERT INCIDENCE, VOLATILITY, AND SPREADS ...... 135 3.6.1 OLS, 2SLS AND FIML RESULTS FOR ALL DECILES ...... 135 3.6.2 OLS, 2SLS AND FIML RESULTS FOR THICKLY-TRADED DECILES ...... 140 3.6.3 OLS, 2SLS AND FIML RESULTS FOR MODERATELY-TRADED DECILES ...... 143 3.6.4 OLS, 2SLS AND FIML RESULTS FOR THINLY-TRADED DECILES ...... 146 3.7 PROBABILITY OF REAL-TIME SURVEILLANCE ...... 149 3.7.1 MODEL SPECIFICATION ...... 149 3.7.2 EMPIRICAL RESULTS ...... 150 3.8 STRUCTURAL EQUATION ESTIMATES ...... 155 3.8.1 THE SIMPLE MODEL ...... 155 3.8.2 THE FULL INTERACTION EFFECTS MODEL ...... 161 3.9 SUMMARY AND CONCLUSION ...... 165
BIBLIOGRAPHY ...... 168
APPENDIX 1 QUOTES FROM VARIOUS LEAD EXCHANGE WEBSITES ...... 172
APPENDIX 2 ANNOTATED BIBLIOGRAPHY ...... 175
vii
Certification
I hereby declare that this submission is my own work and to the best of my knowledge it contains no materials previously published or written by another person, or substantially proportions of material which have been accepted for the award of any other degree or diploma at UNSW or any other educational institution, except where due acknowledgement is made in the thesis. Any contribution made to the research is explicitly acknowledged in the thesis. I also declare that the intellectual content of this thesis is the product my own work, except to the extent that assistance from others in the project’s design and conception or in style, presentation and linguistic expression is acknowledged
Shan Ji 30th March 2009
viii
Acknowledgements
If it wasn’t clear to me before, it’s certainly clear to me now that a doctorate is an enormous personal undertaking. While it is my name appears on this dissertation, this has nonetheless been a team effort, and there are a number of people and institutions who have provided me with considerably guidance and assistance and who I wish to acknowledge here.
First and foremost I express my deep appreciation to my beloved parents and wife, and Dawn and Bryce Butterwort for all they have done for me through the years. For their sustained support of my, my education, and of this dissertation.
Professor Rick Harris’ supervision of this research has been magnificent. I am profoundly grateful to Professor Harris for the incredible efforts he made guiding, educating and mentoring me through the entire Ph.D. programme.
A number of organizations have supported my Ph.D. dissertation both financially and materially. SMARTS Group International generously sponsored my scholarship in partnership with Capital Markets Cooperative Research Centre (CMCRC). I thank Mr. Lorne Chambers for his guidance and support to the Ph.D. program. I spent the entire duration of my dissertation working out of the offices of SMRATS Group, firstly as a surveillance alerts developer, then as a senior business analyst. Overwhelmingly my colleagues have been a great source of stimulation and support.
ix
Finally, I’d like to express my deepest acknowledgements to my principal supervisor Professor Michael Aitken, for creating and leading an organisation as innovative as the CMCRC with which I could achieve so much. Michael, thank you for offering me with this precious opportunity.
x
List of diagrams Figure 1 Ramping ...... 13 Figure 2 Order book for the Misleading Order Strategies Scenario ...... 14 Figure 3 Illustration of a Successful Misleading Order Strategy ...... 15 Figure 4 Illustration of Derivative-Underlying Price Manipulation...... 16 Figure 5 Layering the Order book ...... 17 Figure 6 Two Scenarios of Churning ...... 18 Figure 7 Histograms for Spread Measure before and after log transform ...... 51
xi
List of tables
Table 1 Common Alerts Data Requirements ...... 33 Table 2 List of Securities Exchanges Covered by this Research ...... 43 Table 3 Descriptive Statistics for average Quoted Spread and Effective Spread per security per year across 34 Markets for the period 2000-2005 ...... 49 Table 4 Sample Mean of Spreads by Deciles ...... 52 Table 5 Descriptive Statistics for Ramping Alerts Incidence across 34 Markets for the period 2000-2005 ...... 53 Table 6 Sample Mean of Alerts Incidence by Deciles ...... 55 Table 7 Random Effects Model Results (Quoted Spread for All Deciles) ...... 59 Table 8 Random Effects Model Results (Quoted Spread for Decile 1) ...... 62 Table 9 Random Effects Model Results (Quoted Spread for Decile 2) ...... 64 Table 10 Random Effects Model Results (Quoted Spread for Decile 3) ...... 66 Table 11 Random Effects Model Results (Quoted Spread for Decile 4) ...... 68 Table 12 Random Effects Model Results (Quoted Spread for Decile 5) ...... 70 Table 13 Random Effects Model Results (Quoted Spread for Decile 6) ...... 72 Table 14 Random Effects Model Results (Quoted Spread for Decile 7) ...... 74 Table 15 Random Effects Model Results (Quoted Spread for Decile 8) ...... 76 Table 16 Random Effects Model Results (Quoted Spread for Decile 9) ...... 78 Table 17 Random Effects Model Results (Quoted Spread for Decile 10) ...... 80 Table 18 Random Effects Model Results (Effective Spread for All Deciles) ...... 83 Table 19 Random Effects Model Results (Effective Spread for Decile 1) ...... 85 Table 20 Random Effects Model Results (Effective Spread for Decile 2) ...... 87 Table 21 Random Effects Model Results (Effective Spread for Decile 3) ...... 89 Table 22 Random Effects Model Results (Effective Spread for Decile 5) ...... 91
xii
Table 23 Effects Model Results (Effective Spread for Decile 5) ...... 93 Table 24 Effects Model Results (Effective Spread for Decile 6) ...... 95 Table 25 Effects Model Results (Effective Spread for Decile 7) ...... 97 Table 26 Effects Model Results (Effective Spread for Decile 8) ...... 99 Table 27 Effects Model Results (Effective Spread for Decile 9) ...... 101 Table 28 Random Effects Model Results (Effective Spread for Decile 10) ...... 103 Table 29 List of Securities Exchanges Covered by this Research ...... 124 Table 30 Descriptive Statistics for 24 Markets in year 2005 ...... 129 Table 31 Correlation between Dummy Variables ...... 131 Table 32 Regression Results for Potential Endogenous Equations for all deciles across 24 Securities Exchanges in 2005 ...... 136 Table 33 Regression Results for Potential Endogenous Equations for thickly-traded deciles across 24 Securities Exchanges in 2005 ...... 140 Table 34 Regression Results for Potential Endogenous Equations for moderately-traded deciles across 24 Securities Exchanges in 2005 ...... 143 Table 35 Regression Results for Potential Endogenous Equations for thinly-traded deciles across 24 Securities Exchanges in 2005 ...... 146 Table 36 PROBIT Analysis of Real-time Surveillance System Deployment ...... 151 Table 37 Structural Equation Estimates for the Simple Model ...... 156 Table 38 The Full Interaction Effects Model Estimates ...... 164
xiii
xiv
Chapter 1
Manipulation: A Survey and Literature Review
1.1 Introduction Financial markets have deeply penetrated to almost every corner of the world, from contentious policy making to peoples’ daily lives. Wall Street, NASDAQ, bear market or bull market, those terms appear with high frequency from vast media and people’s conversations. The recent Sub-prime Melt Down in the U.S. has not only severely stricken investors’ confidence but also hit hard the world economy. Multi-billions of dollars have been pumped into the banking system and problematic financial institutions for the purpose of maintaining sufficient liquidity and avoiding more collapses such as Lehman Brothers. It’s perhaps a little bit late to call for tougher regulations to save the sub-prime mortgage industry. However, a vast of academic and empirical literature has shown that well-functioning markets are directly connected to the perception of fairness of the market (La Porta, Lopez-de-Silanes, Shleifer and Vishny 1997; Bhattacharya and Daouk 2002).
When the sub-prime crisis is cured and the order of the financial markets is restored and the prosperity can be expected again. With the pain still fresh, it can be expected that investors will insist on a “fair market” which has a high level of integrity and efficiency. One crucial measure to evaluate the integrity of a securities market is the level of market misconduct. For example, insider trading and securities market manipulations are two common types of market misconduct that can be observed. Aggarwal and Wu (2006) argue that the possibility that stock markets (both developed 1
and emerging) can be manipulated is an important issue for the regulation of trade and the efficiency of the financial market. As a result, more and more securities exchanges have demonstrated their commitment to the twin goals of market efficiency and market integrity.
Securities market manipulation can be defined in many different ways. The Centre for Futures Education defines market manipulation as illegal acts of creating a false impression of trading volume or price for a security. The New York Stock Exchange expounds that securities market manipulation is illegal action of buying or selling a security for the purpose of creating false or misleading appearance of active trading or for the purpose of raising or depressing the price to induce purchase or sale by others. The focus of this research paper will be on securities market manipulation which always relates to transactions as distinguished from insider trading which is driven by information.
Securities market manipulations can occur in a variety of ways. For example, by purchasing a large amount of stock, a broker can drive the price up. If that trader can subsequently sell those shares and if the price does not revert before completing his sales, then the broker can profit from such a trading strategy.
The rest of this chapter is organized as follows. In section 1.2, the review of literature on market manipulation will be given. In section 1.3, a series of common securities market manipulation strategies will be explained: • Ramping • Bait and Switch • Wash Trades • Derivative/Underlying Price Manipulation • Cornering the Market • Squeezing the Market • Unusual Expiration Day Activity • Layering the Order Book • Churning • Front Running
2
Section 1.4 will define the surveillance alerts that have been designed for detecting the incidence of these common market manipulations described in section 1.3.
3
1.2 Literature Review Securities market manipulation, no matter the forms of its existence, temporarily distorts a security’s price when manipulation strategies are successfully deployed. Perhaps a sensible question to ask is whether securities market manipulation is worth the effort of the academia to study and the energy of government (regulators) to act against it.
Although there perhaps has been no formal research conducted on the laws and regulations against securities market manipulation, Bhattacharya & Daouk (2002) report that up to 1998, there are 103 countries with stock exchanges and 87 of them having insider trading laws or regulations. Carlton and Fischel (1983) depict the argument in academia about the necessity of those insider trading laws or regulations as some believe that equilibrium price provides a reliable and efficient source of power to aggregate information effectively, and thus reduce or eliminate information asymmetries in the economy. Bhattacharya and Spiegel (1991) provides solid ground in theory to prove the severity of insider trading and the importance of laws and regulations against it. Their research, based on a two-date exchange economy, shows that the risk premium on a security can be completely characterized by the information and stock held by the market’s outsiders; so if insider trading laws and regulations do not exist, the market may fail completely as an aggregator of equilibrium price. A good example would be when the majority of the non-informed traders in the market believe they are severely disadvantaged by information asymmetry, they will not trade with the informed traders, which directly cause a liquidity collapse.
The same objections apply to securities market manipulations. When a securities market is full of manipulators, no investors will have confidence to invest their money in the market. Without sufficient investors, companies would be reluctant to get listed on the market raising the cost of capital and damaging overall social welfare (e.g., superfund’s performance). Consequently, the understanding of securities market manipulation has wide and critical economical, legal and social impact. In the next section, theoretical and empirical literature will be reviewed in terms of the existence
4
of manipulations in securities market, the forms of securities market manipulation and the relationship between volatility, spread and securities market manipulations.
1.2.1 The Existence of Manipulation in Securities Market Knowing the critical role manipulations can play in securities market, let us firstly have a glance at the likelihood of their existence. Perhaps a more precise terminology we should use here is profitable securities market manipulation as Jarrow (1992) defines it as large traders, those with market power, manipulate prices to their advantage and generate profits at no risk. Allen and Gale (1992) defines securities market manipulations and insider trading by defining trade-based manipulation as a trader attempting to manipulate a stocks imply by buying and then selling, without taking any publicly observable actions to alter the value of the firm or releasing false information to change the price. In contrast, Van Bommel (2003) looks at non- manipulation situations in which traders gain abnormal returns by spreading rumours in the market about their trades.
Hart (1977) perhaps is the very first study trying to prove the existence of profitable manipulation strategies in securities market. This paper builds up a time homogenous price process model in an infinite horizon, deterministic economy and shows that opportunities always exist for profitable manipulation if the economy is dynamically unstable and under certain cases even when the economy is stable. The stability of an economy in this study refers to the stability of market equilibrium.
In 1992, a series of studies were published with a common theme of providing a general model for the existence of securities market manipulations in stochastic economy with time dependent price processes. Jarrow (1992) investigates whether large traders, whose trades change securities’ prices, can gain profits through manipulation strategies. Again, one of the underlying assumptions of this study is that those large traders have no private information. This paper concludes that the existence of profitable market manipulation strategies is related to the time asymmetry in the sensitivity of price changes to the speculator's trades. That is, as the price changes due as a result of large traders’ manipulation strategies, noise traders follow those manipulators to trade with a lag with the belief of price momentum in
5
which increase in price caused by the speculator’s trade at one date tends to increase prices at future dates.
Allen and Gorton (1992) employ another theory to demonstrate the general existence of securities market manipulations. Their model is based on ‘Asymmetry of Price Elasticities’ which depicts the natural asymmetry between liquidity purchases and liquidity sales. When the likelihood of liquidity sales becomes more than liquidity purchases, the liquidity sales turns out to be less informative because it is less likely that the trader is informed. The bid price then moves less in response to a sale than the ask price does in response to a purchase. This asymmetry of price elasticities can create an opportunity for profitable manipulation strategy in which a manipulator can repeatedly buy stocks, causing a relatively large effect on prices, and then sell with relatively little effect.
On the other hand, Allen and Gale (1992) assert that when all agents in a market have rational expectations and maximize expected utility, profitable securities market manipulations still exist due to asymmetric information. The information asymmetry Allen and Gale refer here is the belief of the existence of informed traders rather than the existence of private information. Traders are uncertain whether a large trader who buys the stock does so because he knows it is undervalued based on his private information or because it is part of his manipulation strategy. In other words, it is this pooling equilibrium allowing profitable securities market manipulation to exist under general terms. The definition of pooling equilibrium given by the Dictionary of the Social Sciences (Calhoun, 2002) is equilibria that arise in economic interactions in the presence of incomplete information, where one side of the market has more information than the other side.
Aggarwal and Wu (2006) extend the Allen and Gale (1992) by incorporating information seekers and arbitrageurs into the pooling equilibrium model. This paper provides evidence to show why manipulation strategy can be successful when the manipulator trade in the presence of other trades who seek out information about the stock’s true value. In a market without manipulators, information seekers improve market efficiency by pushing prices up or down to the level private information points
6
to. In a market with manipulators, those information seekers are the ones being manipulated as they can’t distinguish between a market manipulator and an informed trader. This worsens the market efficiency from the perspective of price transparency.
In conclusion, the existence of profitable securities market manipulations has been firmly approved. This suggests a strong role for government regulations to discourage manipulation.
1.2.2 The Forms of Securities Market Manipulation Securities market manipulations exist in a wide range of forms though the overall aim is to drive the security price to the direction beneficial to the manipulator who then liquidates his holdings of the security at a price better than the portfolio establishment price for a profit.
Two traditional forms of securities market manipulations are Corner the Market and Squeeze the Market. They will be explained in details in Section 2 but in general, those two manipulation strategies are often conducted together and the essence is to forcefully shift the equilibrium price by gaining dominant control over the supply of a security. Allen, Titov and Mei (2006) analyse the expected utilities of the uninformed, the arbitrageurs and the manipulator and show that cornering the market can occur when everybody is behaving rationally, which is consistent with Aggarwal and Wu (2006) extend the Allen and Gale (1992). By examining a hand-collected data set of stock market and commodity corners which occurred between 1863 and 1980 in the U.S., this paper finds strong evidence that large investors and corporate insiders possess market power that allows them to manipulate prices. In addition, this paper also suggests that corners normally occur when there is bad news.
Merrick, Naik and Yadav (2005) investigate and present a specific example of market manipulation, Squeeze the Market, detailing the price effects alongside trading positions of participants. With a detailed analysis on the physical delivery squeeze in the March 1998 Long-Term U.K. Government Bond Futures contract traded on LIFFE, this paper depicts a simple squeeze strategy which involves
7
• Buying up the cheapest to deliver bond issue and taking a substantial long position in the bond future • By restricting supply this increases the price of the cheapest-to-deliver bond and also forces participants with shorter term futures contracts to deliver higher value bonds instead.
Jarrow (1992) sheds some lights on the possible reasons behind successful squeeze the market strategy. First of all, the short traders may not realize the market is cornered, because he cannot observe the speculator's trades. Secondly, it may be that the speculator has special information about a technical corner, rather than an actual corner, which the other traders do not share. A technical comer occurs when the speculator's holdings exceed the floating supply, those shares available for sale, and the floating supply is less than the actual supply of shares outstanding. An example is provided by Cornell and Shapiro (1989) as shares may sit in trusts or escrow accounts that cannot (or will not) be sold.
Kumar and Seppi (1992) extend the Kyle (1985) Model and discover that uninformed investors can make profits by taking positions in futures contracts with cash settlement followed by manipulations of prices of the underlying securities. If the manipulator’s futures position is larger than his/her spot position, the net expected gain from this manipulation strategy (i.e., profit on futures less loss on the spot) is positive. The major reason behind is the imperfect informational linkage of futures and the underlying markets which leads to “price pressure” in the futures market. To make this manipulation strategy work, noise traders are necessary in the futures market, which is again consistent with the pooling equilibrium theory.
Drudi and Massa (2005) conduct a unique case study of price manipulation in parallel markets with different transparency by using trading data from the Primary and Secondary Treasury Bond Market in Italy. The design of the Treasury Bond Market in Italy is very exceptive as it consists of a Primary Market which is based on uniform- type auctions, with a uniform cut-off price paid by all winning bidders; and a Secondary Market in which treasury bonds are traded continuously. It is not obscure that the primary market is less transparent than the secondary market since the auction
8
price, overall demand and bonds allotment won’t be known when the primary market closes. This study discovers that the informed dealers with positive news can profit by simultaneously placing bids in the primary market and sell in the secondary market, repurchasing when the primary market closes.
Manipulation of Closing Price becomes the theme of a number of studies. Harris (1989) reports the existence of a large mean day-end transaction price change in the U.S. market between December 1981 and January 1983. Hillion and Souminen (2004) find that broker manipulates the closing price of a stock precede large customer trades in order to improve customer’s impression of his execution quality. An earlier study by Flexison and Pelli (1998) provides empirical evidence found in the Finnish securities market supporting Hillion and Souminen’s theory. Carhart, Kaniel, Kusto and Reed (2002), and Bernhardt and Davies (2005) assert mutual funds manipulate shares’ closing prices at the end of evaluation period to improve fund performance as closing price is a common performance benchmark. Such manipulation strategy is also known as “Painting the Tape”.
A couple of empirical researches also study the expiration-day effect. Stoll (1987), and Chamberlain, Chueng and Kuan (1989) find empirical evidence in the North American markets that on the expiration day of index futures/options, the price mean- reversals are significantly higher than month or quarter end without index futures/options expiration. Stoll and Whaley (1991) suggests that the change of settlement procedure to use next day’s opening price in New York Futures Exchange and New York Stock Exchange may only shift the position of expiration-day volatilities. This provides another reason for the manipulation of closing price. Although, Corredor, Lechon and Santamaria (2001) don’t find any significant expiration effect on returns in the Spanish market which, as a small and less liquid market, is expected to have even stronger evidence.
1.2.3 Volatility, Spread and Securities Market Manipulations Having seen the various forms in which securities markets manipulations can exist, now let us lay our sight on the relationship between securities market manipulations and various market attributes.
9
Hart and Kreps (1986) laid the foundation for the connection between securities market manipulations and volatility. Traditional theory believes speculation stabilizes prices because speculators buy when the prices are low and sell when the prices are high. But other researches show that speculators will buy when the chances of price appreciation are high, which may or may not be when prices are low. This paper discovers that even though non-speculators and speculators alike behave rationally and speculators are competitive, speculation can destabilize prices. Applying this theory to a world with the existence of securities market manipulations, two propositions can be drawn. i) Price manipulators, as a kind of speculators, conduct market manipulation when they believe that profit can be made by doing so. This would destabilize security prices or increase the volatility of security prices. ii) Noise traders, another kind of speculators, follow manipulators to trade since they cannot differentiate informed traders and manipulators. This would also increase the volatility of security prices. Stoll (1987, 1991), Chamberlain, Chueng and Kuan (1989), Chiou, et al (2007) all find empirical evidence suggesting the volatility of security prices is higher during the period of manipulation.
Foucault (1999) develops a Theory of Order Placement which connects volatility, order placement strategies and spread. In Foucault’s theory, order placement strategy consists of two components, Order Type and Order Aggressiveness, which will be defined first. There are two basic order types available for traders to choose from. Market order is submitted without a price which will be executed against the prevailing best price and thus, known as the source of liquidity supply. On the contrary, limit order, which is submitted with a price and stored in the order book waiting for future execution with market orders, consumes liquidity supply. When the non-execution risk is high, traders will use market orders to gain immediate execution; when the pick-off risk is high, limit orders turn out to be a better choice. Order aggressiveness refers to how close the order price is to the prevailing best price when the order is entered or amended. Foucault’s theory predicts that when the volatility of security price increases, traders will tend to hold limit orders rather than
10
market orders to reduce the pick-off risk at the cost of non-execution risk being increased. When execution risk is high, liquidity traders are under the pressure to trade immediately upon arrival because the probability of being executed with a limit order is small. For this reason, traders are willing to place market orders at more unfavourable pries, which result in limit order traders to be less aggressive by posting larger spread in order to take advantage of liquidity traders.
Aitken, Almeida, Harris and McInish (2007) provide evidence supporting Foucault’s Theory of Order Placement. They conclude that hedge funds with short-lived information face high cost of non-execution, and thus their Order Placement Strategy is very aggressive. Insurance companies and mutual funds with the emphasis of cost control tend to be less aggressive.
Comerton-Forde and Putnins (2009) studies the effects of closing price manipulation in an experimental market to evaluate the social harm caused by manipulation. They find that manipulators, given incentives similar to many actual manipulation cases, decrease price accuracy and liquidity, thereby undermining economic efficiency. They conclude that the mere possibility of manipulation alters market participants’ behaviour, leading to reduced liquidity.
11
1.3 Securities Market Manipulations In this section, common securities market manipulations will be described.
1.3.1 Ramping Consistent with the overarching goal of maintaining market integrity, a key goal of a securities market must be to ensure that no one investor can manipulate prices for their benefit, that is, deliberately cause a short term supply/demand imbalance. The ability to manipulate a market would be difficult if individual investors were to invest primarily on their own account. However, given that investors now congregate in funds, the effective size of these new types of investors means that manipulation is feasible. Most funds base their quoted prices and value off of the closing prices of securities in their portfolio. Unusual price movements which revert the following day – especially at quarter ends, may indicate market manipulation to artificially inflate the price of securities. This type of market manipulations is referred as Ramping or Painting the Tape specifically referring to fund managers manipulating security’s closing price at the end of the evaluation period.
A successful ramping case normally evolves in two stages – Marking the Close and Reversal at the Start of the next Trading Day. Marking the Close is a form of price manipulation describing the practice of executing purchase or sale orders at or near the close of the trading session to raise or lower the closing price or to raise or lower the bid or offer artificially for the purpose of reducing margin or net capital requirements for enhancing profit and loss, or to influence the mark-to-market for credit or reporting purposes if holding a large position in the derivatives contract.
Significant price changes at the end of the day may also be explained by reasons other than a participant trying to drive the price for manipulative reasons, for example, information announcements. If the price changes substantially at the end of a day and then reverses quickly at the start of the next trading day due to manipulator’s liquidation, the possibility of such case becoming ramping manipulation will be notable. Figure 1 represents a successful ramping case.
12
Figure 1 Ramping
1.3.2 Unusual Expiration Day Activity Unusual Expiration-Day Activity in its essence is very similar to Ramping but occurs during the "triple-witching" hour - the last hour of trading on days on which index futures, index options and options on index futures expire simultaneously. The purpose of manipulating closing prices of index stocks is not obscure. For example, long position holders of index derivatives will be settled at better price if they can successfully manipulate prices of index stocks upward.
1.3.3 Misleading Order and Trading Strategies Order depth, a widely-used measure of market liquidity, becomes a popular target for market manipulations via Misleading Order and Trading Strategies. Participants carry out misleading order and trading strategies both in the auction period and in continuous trading which are designed to give false perception of order depth on either the bid or ask side of the market. When those strategies are successfully deployed, extra demand or supply for a security can be created, while the participant trades on the other side of the market at more favorable prices.
13
One form of misleading order and trading strategy is Bait and Switch which is described through the following example. Assume broker B1 intends to clear his holding of 10,000 shares of S1. The prevailing order book can be illustrated by Figure 1 below.
Figure 2 Order book for the Misleading Order Strategies Scenario
It can be seen that prevailing best bid/ask price is $11.25 and $11.35, which creates a bid-ask spread of $0.10. Further assume the price tick of security S1 is $0.05. Rather than trading with bids at $11.25, broker B1 enters a bid with price $11.30 and volume 10,000. The behaviour of broker B1 draws attention from other investors and some of them subsequently enter bids at $11.30 as well. Once the total depth of bids at $11.30 from other investors approaches to 10,000, broker B1 withdraws his bid at $11.30 and simultaneously enters a market order (ask) with volume 10,000 which gets traded with remaining bids at $11.30. Figure 2 below illustrates this Misleading Order Strategy. The succesful deployment of this strategy helps broker B1 increase the potential execution price from $11.25 to $11.30.
14
B1 enters a market order at B1 deletes this $11.30 to trade order when with those bids there is enough order depth created
Figure 3 Illustration of a Successful Misleading Order Strategy
1.3.4 Wash Trades Manipulators conduct Wash Trades by actively trading on the market for a security between two accounts that they control, typically buying through one broker, and simultaneously selling through another. Wash trades involves no change in the beneficial ownership of the securities. One obvious intention of Wash Trades is to give false impression of active trading of the security being manipulated, which may attract day-traders to trade. Wash Trades can also be utilized as an avenue for brokers to increase their market share in an instrument leading up to a secondary float of shares. For example, in Australia, lead brokers for the secondary float of Telstra shares (Telstra is the biggest telecommunication company in Australia) were chosen on the basis of existing market share, which may potentially encourages brokers to conduct Wash Trades to compete for the lead broker position.
1.3.5 Derivative-Underlying Price Manipulation In today’s uncertain financial environment, derivative instruments have been widely deployed for hedging and speculating. According to the Bank for International Settlements, the total market value of global derivatives has exceeded $516 trillion in 2007. This makes derivative instruments as heavily manipulated as equities.
Rather than directly manipulating the price of derivative instruments, manipulators often choose to detour by conducting Derivative-Underlying Price Manipulation. 15
Manipulators will take a highly leveraged position1 in a derivative security and then manipulate the price of the underlying security to improve the value of their derivative position (e.g., increase the price of call options or decrease the price of put options). This distorts the true value of the underlying security and creates unnecessary intraday volatility. According to the Strait Time (8 March 2008), recently a Derivative-Underlying Manipulation case was successfully prosecuted in Singapore where two proprietary traders manipulated the price of the Straight Times Index by trading in 12 of the constituent stocks, which made their derivative positions on those constituent stocks profitable. The manipulators then clear both of their positions on the derivative securities and underlying securities to realize the profits. The two manipulators were each fined SG$100,000 (approximately AU$80,000).
3. Clear the position on both the underlying security and the derivative security at a certain stage to realize the profit
2. Then manipulate the 1. Establish the position price of the underlying in the derivative security security in order to first improve the price of the derivative security
Figure 4 Illustration of Derivative-Underlying Price Manipulation
1.3.6 Layering the Orderbook Layering the Orderbook is a form of Misleading Order and Trading Strategy in which a manipulator places a large number of differently priced orders below the best bid price or above the best ask price to create fake appearance of multiple demand or supply sources for a security. In anonymous markets, other participants just see many orders and don’t realise they are all for the same investor. A successful case of
1 Extensive futures positions can reduce the flexibility of manipulators to meet margin requirements, to cancel and replace orders, and to execute on very short-term arbitrage opportunities, etc. 16
Layering the Orderbook may provoke other investors to trade, which could help to either raise or lower the price of the security in the manipulators favour. For example, a manipulator places many bids at different price level to bring the market up, to a level that the manipulator wants to sell at. The manipulator then submits offers that get traded immediately at the favourable price, and withdraws those fake bids after the trades.
Figure 5 Layering the Order book
1.3.7 Churning Churning is normally conducted by a group of brokers/traders who pass share parcels of a security within the group in order to create a high turnover for the security being manipulated but very low net turnover for the group on that security. Figure 3 below illustrates two Churning scenarios. The first one is conducted by Broker 1 (B1) and Broker 2 (B2). B1 sells 10,000 shares of security S1 to B2 then B2 sells 10,000 shares of security S1 back to B1. By doing this, a total turnover of 20,000 volume unit is created for security S1 while the net turnover for B1 and B2 on security S1 is zero. The second scenario is conducted by B1, B2 and Broker 3 (B3) on security S1. B1 sells 10,000 shares of S1 to B2; B2 then pass that parcel of shares to B3 who finally finishes the churning cycle by selling that parcel of shares back to B1. Similar to the
17
first scenario, a total turnover of 30,000 volume unit is created for S1 while none of the three brokers holds a position on S1 at the end of the churning cycle.
Figure 6 Two Scenarios of Churning
Several motivations could initiate churning. Some manipulators may try to increase their commissions by excessively trading between each other (in this case, a group of client accounts will be used for settlement); some manipulators pre-arrange churning to create an impression of active market on illiquid securities so that more investors can be attracted to improve the execution price in manipulators’ favor; in some markets, warrant’s turnover has become one of the most important benchmarks for non-institutional investors to determine which warrant to trade. For example, when 10 underwriters issue a total of 10 warrants for Google with similar product structure, non-institutional investors would often rank those warrants by turnover and invest in the ones with high turnover. As a result, a warrant underwriter may collaborate with a group brokers to make use of Churning to increase the turnover of a warrant issued by him in order to compete against warrants issued by other underwriters for the same underlying.
1.3.8 Cornering the Market Cornering the Market is normally conducted on derivatives contracts settled by physical deliveries. To successfully corner the market, a manipulator needs to acquire a large quantity of a physical good that is the deliverables for some derivatives
18
contracts in order to shift the market equilibrium by reducing the supply of that physical good so that strong price pressure can be exerted. For example, when a derivatives contract is cornered, investors who hold short positions on that contract will be forced to close out their positions by buying back the physical good from manipulators cornering the market at a much higher price.
1.3.9 Squeezing the Market Manipulators can bid up the price of a security if they suspect the cumulative short position on a security is high. At some point, investors may be forced to buy back to close their position, which will result in more demand for that security and further driving the price of the security higher. The manipulator can then sell the securities to the market at a higher price. This form of manipulation is normally known as Squeezing the Market that is most effective where momentum traders are present which creates enough demand for the manipulator to sell back to. The Corning the Market strategy is often accompanied by the Squeezing the Market strategy.
1.3.10 Front running Brokers trade not only for their customers but also for themselves. Front running is a kind of stock market manipulations in which a stock broker executes orders on a security for their own account (as principal) before executing orders previously submitted by their customers (as agency). After the broker has made their original transactions, they can expect to close out their position at a profit based on the new price level. Front running may involve either • Brokers buying for their own accounts, driving up the price before executing customer buy orders; or • Brokers selling for their own account, driving down the price before executing customer sell orders.
For example, a broker buys 20,000 shares of a stock for $10 per share just before buying a large block of 100,000 shares for a customer. The broker’s principal trade may drive the price up to $10.5 per share. If the broker is able to sell their newly purchased shares at $10.3, it will have made $6,000 in a few minutes, which is likely
19
to be part of the additional cost to the customer's purchase caused by the broker's principal dealing.
20
1.4 Alerts for Securities Market Manipulations
1.4.1 Introduction In collaboration with the Capital Markets Cooperative Research Centre Limited (CMCRC) and Smarts Group International Pty. Ltd., the author of this dissertation have gained broad knowledge in the area of securities markets manipulation detection by implementing market surveillance alerts for a number of securities exchanges. Some of those exchanges are: • The Australian Securities Exchange (ASX)
• The Saudi Arabian Stock Exchanges (TADAWUL)
• The Dubai Financial Market (DFM)
• The Euronext Stock Exchange (NYSE Euronext)
• Tokyo Commodity Exchange (TOCOM)
• The Singapore Stock Exchange (SGX)
• The Hong Kong Stock Exchange (HKEX)
• The Securities and Futures Commission of Hong Kong (HKSFC)
• The PLUS Market Group (PLUS)
• The Stock Exchange of Thailand (SET)
• The Securities and Exchange Board of India (SEBI)
• Malaysia Securities Commission (MSC)
In Section 1.4, market surveillance alerts that are developed by the author of this dissertation for securities exchanges listed above to detect market manipulation cases will be explained in terms of purpose, data requirements and algorithm design.
21
1.4.2 The Marking the Close Alert 1.4.2.1 Purpose The Marking the Close Alert is designed to detect attempts to manipulate the close price of a security. Marking the Close is normally referred as the first stage of a Ramping case. This alert can also identify Unusual Expiration Day Activity.
1.4.2.2 Data Requirements The Marking the Close Alert is executed on trade level data including trade time and trade price. If trading participants data is provided, this alert can become more informative by pointing out the participant who is responsible for majority of the price movements.
1.4.2.3 Alert Algorithm A Marking the Close Alert will be issued if the following conditions are satisfied: 1) When the security is closed for trading; and 2) The absolute percentage difference between the close price of the security and its price X minutes before closing is greater than the threshold.
The calculation of threshold is described as below. 1) For each trade of a security over the past T days, calculate the absolute percentage difference between the trade price and the price X minutes ago; 2) Assign the absolute percentage difference calculated in 1) to the price change distribution for that security; 3) At last, calculate the mean and standard deviation for the price change distribution for each security. If there are more than 50 observations in the price change distribution for a security, set the threshold to the 3 standard deviations away from of the price change distribution as the threshold for that security; otherwise determine the percentage threshold from the following Price Band-Threshold Table. The rationale behind the threshold calculation is to capture unrepresentative price change. This algorithm has been implemented at more than 30 national exchange and regulators by SMARTS.
22
Last Trade Price of the Security Percentage Threshold Price From ($) Price To ($) 0.00 0.10 20% 0.11 0.25 15% 0.26 0.50 12% 0.51 1.00 10% 1.01 5.00 8% 5.01 10.00 5% 10.01 10000000.00 3%
1.4.3 Reversal the Next Trading Day 1.4.3.1 Purpose The Reversal the Next Trading Day Alert is designed to detect security, which was issued a Marking the Close Alert the previous day, has a price reversal towards the VWAP price X minutes before the previous day’s closing during the first Y minutes of the current day’s trading. Reversal the Next Trading Day is normally referred as the second stage of a Ramping case.
1.4.3.2 Data Requirements The Marking the Close Alert is executed on trade level data including trade time, trade price and trading participants.
1.4.3.3 Alert Algorithm A Reversal the Next Trading Day Alert will be triggered for a security when the following conditions are satisfied: 1) If a Marking the Close Alert was triggered for a security the previous day; and 2) A trade occurs for that security during the first Y minutes of trading on the current day; and 3) The absolute percentage difference between the trade price and the security’s VWAP price X minutes before the previous day’s closing is smaller than a pre-defined threshold (e.g., 50%). 23
1.4.4 The Bait and Switch Alert 1.4.4.1 Purpose The Bait and Switch Alert is designed to identify order strategies both in the auction period and in continuous trading which are designed to give the perception of depth on either the bid or ask side of the market, while the participant submitting the orders trades on the other side.
1.4.4.2 Data Requirements The Bait and Switch Alert requires both order level and trade level data including best bid/offer price, order entry time and price, trade time and price and buying/selling participants.
1.4.4.3 Alert Algorithm A Bait and Switch Alert will be triggered when the following conditions are satisfied: 1) A participant (the suspect participant) enters a bid/offer which improves the prevailing best bid/offer price; and 2) Other participants follow by entering bid/offer at the same price or even better price; and 3) When the total order depth created by other participants at the new best bid/offer exceeds the intended volume the suspect participant wants to trade, the suspect participant withdraws his initial bid/offer; and 4) The suspect participant enters order at the opposite side which gets traded subsequently.
1.4.5 Wash Trade 1.4.5.1 Purpose The Wash Trade Alert identifies trades where there is no change in beneficial ownership of the parcel of shares.
1.4.5.2 Data Requirements The Wash Trade Alert requires trade level data, and client data or participant dealing capacity data including trade time, volume and trading client/broker dealing capacity (e.g., Principal or Agency)
24
1.4.5.3 Alert Algorithm A Wash Sale Alert will be triggered when the following conditions are satisfied: (1) The buy client and the sell client of a trade are the same entity or the dealing capacity of the buy side and the sell side are the same (e.g., both the buy broker and the sell broker are trading for the same and the broker is trading for himself) (2) The number of wash sales conducted by a client/broker on one security exceeds the threshold.
1.4.6 Derivatives/Underlying Price Manipulation 1.4.6.1 Purpose The Derivatives/Underlying Price Manipulation Alert is designed to identify participant who gains profits on his/her derivatives position by manipulating the underlying’s price.
1.4.6.2 Data Requirements The Derivatives/Underlying Price Manipulation Alert requires trade level data for the derivatives instruments and their underlying, including trade time, price, volume and buying/selling participant.
1.4.6.3 Alert Algorithm A Derivatives/Underlying Price Manipulation Alert will be triggered when the following conditions are satisfied: (1) A participant (e.g., client or principal broker) establishes a long (short) position in call (put) option(s) or warrant(s) for an underlying (2) After the long (short) position is established for the call (put) option(s) or warrant(s), the same participant starts continuously buying (selling) the underlying security in order to drive the underlying price up (down) (3) When the price of the call (put) option(s) or warrants(s) increases by a certain percentage, the participant closes his position in the option(s) or warrant(s) to realize the profit
25
(4) After the derivatives position is closed, the participant starts to close his position in the underlying as well (5) At the end of the trading day, the participant holds a zero (or near-zero) position in the underlying security with trivial profit or loss from the day trading in the underlying security
1.4.7 Cornering the Market 1.4.7.1 Purpose The Cornering the Market Alert is designed to identify participant who tries to manipulate the price of futures contracts by dominating the holdings of the underlying security or commodity. 1.4.7.2 Data Requirements The Cornering the Market Alert requires derivatives trading data and underlying holdings data including trade time, price, volume, participant and the participant’s holding quantity of the underlying security of commodity.
1.4.7.3 Algorithm The Cornering the Market Alert will be triggered when the following conditions are satisfied: (1) At the start of a trading day, check each participant’s holding position in securities or commodities that are underlyings for derivatives contracts; (2) If one participant holds the majority of the underlying securities or commodities In the (e.g., more than 25%), issue an alert for Excessive Holdings of Underlyings; (3) During continuous trading, if the trading price of a derivatives contract significantly varies from the reference price (e.g., close price from 3 trading days ago), then check if the underlying of that derivatives contract has been issued an Excessive Holdings of Underlying Alert before; if yes, issue a Cornering the Market Alert for the underlying security and the participant dominating the holding of the underlying security or commodity.
1.4.8 Squeezing the Market 1.4.8.1 Purpose
26
The Squeezing the Market Alert is designed to identify participant who continuously drives the price of a derivatives contract up when the cumulative short position is relatively high in the derivatives contract.
1.4.8.2 Data Requirements The Squeezing the Market Alert requires derivatives trading data and derivatives holding data including trade time, price, volume, participant and participant’s holding quantities of the derivatives contract.
1.4.8.3 Algorithm The Squeezing the Market Alert will be triggered when the following conditions are satisfied: (1) At the start of a trading day, look over the derivatives holding database and calculate the cumulative short position of each derivative contract; (2) If the cumulative short position of a derivative contract exceeds the benchmark (e.g., 30% of the total contracts issued), flag that derivative contract as highly sensitive; (3) During continuous trading, if a participant continuously drives up the price of a derivatives contract which has been flagged as highly sensitive before, issue a Squeezing the Market Alert.
1.4.9 Layering the Order Book 1.4.9.1 Purpose The Layering the Order Book Alert is designed to identify participant who creates a false impression of an active market for a security by placing multiple buying (selling) orders at different price level with the intension of trading at the opposite side with a better price.
1.4.9.2 Data Requirements The Layering the Order Book Alert requires the order level data and trade level data including transaction time, price, volume and participant for orders and trades.
1.4.9.3 Algorithm
27
The Layering the Order Book Alert will be triggered when the following conditions are satisfied: (1) A participant (broker, trader or client) places multiple orders with different price at the bid (ask) side of a security; (2) The same participant subsequently enters orders at the opposite side and those orders get traded; (3) After the trade, the participant quickly withdraws those fake bids (asks) entered before at various price levels.
1.4.10 Churning 1.4.10.1 Purpose The Churning Alert is designed to identify participants-pair that creates a false impression of an active market for a security by trading between each other without holding a substantial quantity of the security overnight.
1.4.10.2 Data Requirements The Churning Alert requires trade level data including trade time, price, volume and participants.
1.4.10.3 Alert Algorithm The Churning Alert will be triggered when the following conditions are satisfied: (1) On every trade, check whether the buy participant-sell participant pair has traded the security before; (2) If yes, increase total turnover from that participant pair for that security by the volume of the current trade and adjust the net turnover in between the participant pair accordingly. For example, assume Broker A is the buy broker while Broker B is the sell broker for the current trade with volume of 5,000 shares. Suppose Broker A was the sell broker while Broker B was the buy broker from a previous trade for the same security and the trade volume was 5,000 shares. Consequently, the total turnover, for that security, from the Broker A- Broker B pair after the current trade is 10,000 shares while the latest net turnover in between the broker pair is zero.
28
(3) At the end of the day, if the total turnover from a participant pair on a single security exceeds the total turnover threshold and the net turnover as a percentage ratio to the total turnover from that participant pair is below the net turnover threshold, issue a Churning Alert.
1.4.11 Front Running 1.4.11.1 Purpose The Front Running Alert is designed to identify participant who executes orders for himself before executing clients’ orders in order to enjoy better execution price. 1.4.11.2 Data Requirements The Front Running Alert requires order and trade level data including order/trade transaction time, price, volume, participant and dealing capacity (e.g., trading as principal or agency).
1.4.11.3 Alert Algorithm The Front Running Alert will be triggered when the following conditions are satisfied: (1) A participant executes a bid (offer) order for a client and the execution moves the security price up (down); (2) Before the execution of the client’s bid (offer) order, if the participant executes bid (offer) order(s) as a principal at a price better than the execution price of the client’s order, flag the execution(s) as potential front running trade(s) and increase the potential front running volume executed by that participant on that security by the volume of the potential front running trade(s); (3) At the end of the day, if the total front running volume for a participant- security pair exceeds X% (e.g., 30%) of the total volume that participant executed on that security during the day, issue a front running alert.
29
Chapter 2
Market Integrity and Market Efficiency: A Cross-Market Comparison
2.1 Introduction After the financial crisis of 2008, more than ever investors prefer to put their money into a “fair market” which has a high level of integrity and efficiency. Accordingly, more and more securities exchanges have declared and begun to demonstrate their commitment to the twin goals of market efficiency and market integrity. NASDAQ states on its website that
“NASDAQ is among the world’s most regulated stock markets, employing sophisticated surveillance systems…to protect investors and provide a fair and competitive trading environment.”
“Offering growth and liquidity, fostering innovative technologies…NASDAQ continues to build the most efficient trading environment…to the benefit of all market participants and investors.”
Appendix 1 contains a sample of relevant statements from the websites of other major world securities exchanges worldwide.
30
Although significant resources have been invested in the improvement of market integrity and market efficiency by the those major stock exchanges, little is known about the direct relationship between market integrity and market efficiency and whether an improvement of market integrity helps in achieving better market efficiency. The purpose of this Chapter is to address these questions directly.
In Chapter 1, a review of theoretical and empirical literature was given for the existence of securities market manipulations and the relationship between manipulations and some market attributes. Hart and Kreps (1986) laid the foundation for the connection between securities market manipulations and volatility; Foucault (1999) and Aitken, Almeida, Harris and McInish (2007) find a negative correlation between volatility and aggressiveness of order placement strategy. When volatility is high, traders submit orders less aggressively because non-execution risk decreases and picking off risk increases, which are eventually reflected in wider spreads. There have been a number of empirical studies conducted to test the relationship between securities market manipulations and volatility, and we would expect a follow-on correlation between volatility and spreads.
However, there has been no direct test of the relationship between securities market manipulations and spreads. One of the fundamental reasons perhaps is the extreme difficulty of collecting data on market manipulations. In this chapter, a random effects correlation analysis will be conducted for the relationship between securities market manipulations and market efficiency. We believe this work to be the first of its kind.
The rest of this chapter is organized as follows. In section 2.2, the research methodology will be specified. Section 2.3 defines the data and measurement used by this research while section 2.4 gives the empirical specification of the statistical regression model. Section 2.5 and 2.6 analyses and discusses the empirical results.
31
2.2 Research Methodology
2.2.1 Market Integrity Defined for this Research Securities market manipulations exist in various forms. Section 1.3 provides an illustration of ten common securities market manipulation strategies. The nature of each manipulation strategy decides the surveillance approach to detection. Though thousands of ways could exist to detect one kind of market manipulation strategy versus another, a series of detection rules (a.k.a., Alerts), which the author has designed and implemented for 12 securities exchanges and regulators around the world are presented in Section 1.4. For the purpose of this research, the Ramping Manipulation Strategy will be the focus, and the combination of the Marking the Close Alert and the Reversal the Next Morning Alert, which is normally used to detect Ramping will become an important part of the research methodology. The reason behind this selection is given below.
Table 1 lists the minimum level of data required by each of the 10 types of market manipulations presented in Section 1.4.
32
Table 1 Common Alerts Data Requirements
Alert Name Data Required (minimum) Marking the Close Alert Trade Level Data Reversal the Next Trading Day Alert Trade Level Data Bait and Switch Alert Order Book Data Trade Level Data Wash Trade Trade Level Data Participant Data Derivatives/Underlying Price Trade Level Data Manipulation Participant Data Cornering the Market Trade Level Data Participant Holdings Data Squeezing the Market Trade Level Data Participant Holdings Data Layering the Order Book Order Book Data Trade Level Data Churning Trade Level Data Participant Data Front Running Trade Level Data Participant Data Deal Capacity Data
From Table 1, it can be seen that Marking the Close Alert and Reversal the Next Trading Day Alert are the only two alerts that can be executed by using the Trade Level Data only (Trade level data includes security, trade time, trade price and volume). All the other alerts require Order Level Data, Participant Data, Participant Holdings Data or Deal Capacity Data. Hart and Kreps (1986) point out that data collection for market manipulations is extremely hard. The only order book data database that can be publicly accessed is NYSE trades, orders, reports, and quotes (TORQ) Database which contains time-ordered transactions for 144 selected stocks for the short three month period from November 1990 to January 1991 for the purpose of an order book audit. Even more so, the participant data required for the surveillance and enforcement of rules violated by other manipulations (and their associated alerts) is strictly confidential to stock exchanges; no publicly accessible database can provide the participant data.
33
Therefore, this research will use Ramping Market Manipulation (which consists of Marking the Close Alert and Reversal the Next Morning Alert) as a proxy for securities market manipulation for the cross-markets analysis.
A recent case detected by the Australian Securities Exchange (ASX) illustrates the behaviour underlying Ramping. On Friday, 29th June 2001 between 4 and 4.15pm the Standard & Poor’s ASX 200 Index (SPI 200) increased 45.5 points following the closing single price auction (CSPA) on the ASX. By market open on the following Monday, this unusual increase was reversed. The last trading day of the financial year always pushes share prices a little higher, but on 29 June the All Ordinaries Index rose by 67 points, or two per cent, and the ASX is concerned market manipulation may have been involved. On 2 July, the index fell by 54 points, as the "ramping" buyers, believed to be fund managers and derivative players, withdrew.
2.2.2 Market Efficiency Defined for the this Research Aitken and Berry (1993) state that academia typically define market efficiency based on information as the market reacts in a speedy and unbiased fashion to information. Once Kendall (1957) argued that stock prices displayed ‘random walk’ behaviour, economists came to realize that random price movements indicated a well-functioning or efficient market. The three standard forms of efficiency come from broad consensus where evidence has shown that markets are at least weak form and often semi-strong form efficient under the Efficient Market Hypothesis (e.g., Fama (1970, 1991 and 1998), Jensen (1978) and Malkiel (1996)). Grossman and Stiglitz (1980) claim that investors will have an incentive to spend time and resources to analyse and uncover new information only if such activity is likely to generate higher investment returns.
Gilson and Krakman (2004) came up with the following general conclusion. The level of market efficiency with respect to a particular fact is dependent on a number of mechanisms • Informed trading, e.g., professionally-informed trading, derivatively informed trading, etc; and
34
• Uninformed trading which is operated to cause that fact to be reflected in market price. Which mechanism is operative depends on the breadth of the fact’s distribution, which in turn depends on the cost structure of the market for information. They further argue that the lower the cost of information, the wider its distribution, the more effective the operative efficiency mechanism and, finally, the more efficient the market.
In order for a market to become efficient, investors must perceive that a market is inefficient and possible to beat. Investment strategies intended to manipulate inefficiencies are actually the fuel that keep a market efficient. However it is often these investment strategies that not only affect the level of efficiency but the integrity of the market place. This is consistent with the pooling equilibrium theory for the existence of profitable securities market manipulations suggested by Allen and Gale (1992) and Aggarwal and Wu (2006).
For the purpose of this research, we shy away from traditional academic notions of market efficiency that tend to focus on information efficiency as previously discussed to a more all encompassing definition which concerns itself with the ability to instantaneously convert cash into securities and back again. The more efficient the market the cheaper is the conversion process; or more conventionally, the lower are transaction costs.
Key components of transaction costs include brokerage costs, market impact costs, and opportunity costs. Unfortunately none of these is directly observable in the data available to us. We therefore proxy transaction costs by measuring (1) The absolute cost of a round trip transaction (the quoted spread) as a percentage of the spread midpoint; and (2) Average cost beyond the midpoint to complete all trades (the effective spread) as a percentage of the quote midpoint; and (3) Average cost for immediate versus more patient trades (the realized spread), again as a percentage of the quote midpoint.
35
These relative bid/ask spreads are widely used and accepted measures of the relevant transaction costs.
2.2.3 Random Effects Model By maintained hypothesis, market integrity affects transaction costs. A lower level of integrity and higher level of market manipulations is hypothesized to raise spreads. Specifically, the null hypothesis of our research is