Remembering 9/11

September 17, 2001: Traders on the floor of the Chicago Board Options Exchange pause to reflect on the lives lost in the September 11 terrorist attacks.

Photo courtesy of CBOE Remembering September 11 Remembering September 11

By Will Acworth and Robert Plummer

On the tenth anniversary of the Sept. 11 attacks on the World Trade Center, it is appropriate for the futures and options industry to remember the lives that were lost and the spirit of cooperation that helped the markets reopen and the firms resume operations. We are observing the anniversary of the attacks by republishing excerpts from the stories we ran in the October/November 2001 issue of Futures Industry and listing the names of the more than six dozen industry professionals who lost their lives on that day. Their full obituaries, posted on our website, tell the incredible professional and personal stories of our friends and colleagues who perished.

hen the two planes slammed the attacks, but moved immediately to shut futures industry began the urgent but dif- into the World Trade Center on its exchanges and evacuate office buildings ficult process of reopening its markets. Call- WSept. 11, they struck right at the in the downtown area. Traders and man- ing on expertise gained from the Chicago heart of the futures community. The attacks agers watched the horror in New York un- flood, the collapse of Barings Bank, and destroyed the New York Board of Trade’s fold on their television screens, and sought preparations for the Year 2000 computer physical trading facility and blocked ac- desperately to reach colleagues, friends and date change, the industry moved imme- cess to the New York Mercantile Exchange loved ones in New York. diately to backup facilities and set about building, forcing both markets to close for In Washington, members of the FIA staff restoring connections and reestablishing several days. Among the thousands who gathered in John Damgard’s office as news relationships. Exchanges and firms set aside died when the towers collapsed were many of a plane hitting the World Trade Center traditional rivalries and reached out to the professionals from the futures industry. circulated through the office. Damgard’s most stricken members of the industry with Dozens of firms in the World Trade Center office overlooks the intersection of Penn- offers of help. The government stepped in towers and the surrounding buildings were sylvania Ave. and 20th Street—five blocks with timely relief, cutting through the red active in futures-related business. Thank- from the White House. The staff watched tape to help the industry reopen in a radi- fully many were able to evacuate before the in horror as the news showed a second plane cally different environment. towers collapsed, but their places of busi- striking the other tower. A few minutes later For many managers in the futures in- ness were damaged or destroyed and many a large passenger jet appeared in the Wash- dustry, one of the most difficult things to of their employees were deeply affected by ington sky. The FIA staff watched as the handle about the Sept. 11 attacks was the the tragic events they witnessed. Two firms plane awkwardly banked away from the emotional impact of the disaster. More lives in particular suffered catastrophic loss of White House, headed south and crashed were lost than at Pearl Harbor or D-Day, life—Cantor Fitzgerald and Carr Futures. into the Pentagon. and many survivors were haunted by the Chicago was spared the direct effects of After the initial shock and disbelief, the images of death that they saw that day.

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SMW Trading: Day of Terror 13, just two days after the attack. Escaping Just in Time for Cantor Fitzgerald One of the few pieces of positive news One firm that came very close to losing its Although Cantor Fitzgerald was primarily for Cantor amid the tragedy was that many people was SMW Trading, a Chicago-based a bond firm, its subsidiary eSpeed operated members of Cantor’s technology staff typi- FCM that cleared for locals on Nymex and an electronic system for trading fixed in- cally came to work after 9:00 and therefore Remembering missed the first strike. Those employees Nybot. SMW had an office on the 85th come futures and certain energy commodi- floor of One World Trade Center, just a few ties. Many of its employees were drawn became the backbone of the company’s op- floors below the point of impact. Incredibly, from the futures industry and the Nymex. erations in the U.S. and worked with the everyone in the office made it out safely. Cantor occupied several floors at the London office to sustain Cantor’s position Jonathan Markowitz, one of the firm’s very top of One World Trade Center, the as one of the primary inter-dealer brokers September 11 in the Treasury market. partners, normally worked in Chicago, but first tower to be hit and the second to col- on Sept. 11 he happened to be on one of his lapse. None of the 658 people in its office As a result, the company retained much monthly visits to the New York office. In an at the time of the attack—about two-thirds of the operational expertise it needed to interview with Futures Industry, he said the of its total workforce—were able to evacu- regain its footing in a makeshift office in whole building moved sideways when the ate. Frederick Varacchi, eSpeed’s president New Jersey. plane hit then snapped back, sending com- and chief operating officer, was one of the After the disaster, Cantor set up a coun- puters sliding off desks and crashing onto many Cantor employees fatally trapped in seling center at the Pierre hotel in New the floor. the building by the attacks. York. Cantor also set up a relief fund to Unlike other offices on that floor, there Howard Lutnick, Cantor’s top executive, provide financial assistance to the Cantor was no fire, at least not initially visible, and vowed to keep the firm going, but the dev- families who lost loved ones in the tragedy. no loss of power or telephones. Even so, the astating loss forced the company into a fun- 20 or so staff in the office decided to evacu- damental change of strategy. Cantor shut Carr Futures: At the Epicenter ate because of memories of an earlier terror- down most of its voice broking operation, Before the Sept. 11, Carr Futures was one of ist attack in 1993. which once handled roughly a quarter of all the 10 largest FCMs in the U.S. In numeri- Remarkably, there was no panic in the over-the-counter trades in Treasury bonds. cal terms, Carr’s losses were much smaller stairway. After the 1993 bombing, the Instead, the company put all its resources than Cantor’s, but the firm was just as hard building management had installed better into eSpeed, which resumed trading Trea- hit. Sixty-nine of the firm’s employees did lighting and many firms had established suries via its all-electronic platform on Sept. not survive the attacks. clear procedures for ensuring a smooth evacuation. Indeed, one of the positive surprises of that day was how many peo- ple in the towers managed to escape. As People make their way amid debris near the World Trade Center in New York on Sept. 11, 2001. the SMW staff descended from the 85th Photo courtesy of AP/Wide World Photos. floor, they passed several places where burning jet fuel had come down the eleva- tor shafts. Fortunately the way was clear all the way down. “Single file, it took us about an hour and twenty minutes to get out of the building,” Markowitz said. Just as he was about to exit the build- ing, Two World Trade Center collapsed. “I stopped on the 30th floor to talk with the firemen. We got separated by the crowd, so the first part of our group was out of the building when the first tower collapsed. I was still inside with my two staffers and I actually saw the shock wave coming to- wards me, and I had people still in the stair- well behind me.” “A couple of guys in the first group out- ran the shock wave, but two people ducked down into a subway. They were in pretty serious shape because they inhaled a lot of dust,” he recalled.

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Didier Varlet, the company’s chief execu- sources to manage this kind of situation, the to use hotels as their temporary offices. tive officer, was on vacation in Spain on the crisis center,” Varlet said. “Our first priority Lehman’s investment bankers, for example, day of the attack. As soon as he heard the was to identify how many people survived took over an entire midtown Sheraton. news, he set about organizing a response. and who was in the office.” Other firms moved into space generously The first step was to separate the operational “Obviously, the first thoughts were for offered by their competitors, and many peo- issues from the human management issues, the people from the office who survived this ple worked at home. In many cases, trad- and set up different teams to handle each tragedy. We made a significant effort to do ers had to be split up and put into different aspect of the disaster. anything we could to help them. But you buildings for several weeks while their firms On the operations side, the firm’s systems also have people in the offices of the bank, looked for a more permanent home. were completely backed up and the London even in our offices in London and Paris and One of the more inventive solutions to this and Chicago offices took action the same other locations in the world, who had a problem came from Refco, which moved 25 day to handle the customer business. Carr contact with the New York office. We had traders into the Subotnick Center, a mock updated its web site throughout the crisis to make sure that we gave support to all trading floor at Baruch College on 25th with detailed information for customers these people.” Street, between Third Avenue and Lexington. on the recovery process, including contact The classroom was only two years old numbers for the replacement trading desks The Scramble and was outfitted with the latest gear: com- in London and Chicago. for Office Space puters with T1 connections to the Internet, Carr immediately began the process of More than 13 million square feet of office quotes and data from Reuters and CQG, tracking down which employees had sur- space in lower were destroyed projection televisions for tracking news, vived the attacks and which were missing. by the collapse of the two World Trade Cen- and an electronic wall display with real-time With fixed line telephone connections sev- ter towers, according to real estate experts. market prices. In many ways, the classroom ered and cell phone circuits almost totally Making matters worse, thousands of work- was more advanced than Refco’s own facili- jammed, the company resorted to posting ers were displaced from the World Financial ties at the time. contact information on its web site and Center, One Liberty Plaza, and other office The 25 traders used the classroom for asked local television stations to broadcast buildings adjacent to Ground Zero that almost a month after the attacks, trading a toll-free number, hoping that this would were closed because of the damage. futures on , silver, crude oil and other reach the surviving employees. As a result, one of the first priorities in the , before the company found “We immediately decided to make our recovery effort was to find office space for enough space at a new facility to reunite all office in Chicago, which had all the re- dislocated workers. Some firms were forced of its traders.

Photo courtesy of Thomson Reuters.

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“Baruch did a superlative job. They pro- A Building Destroyed, schedule, with just 90 minutes of trading vided us with everything we needed. All But Nybot Carries On allotted to each . Exchange of- we had to bring were the wall clocks and Mark Fichtel, president and CEO of the Ny- ficials said the same amount of trading was the trading tickets,” said Jeffrey Bauml, the bot at the time of the attack, felt a tremble going through the exchange even with the head of Refco’s sugar desk and a former Ba- when the first plane hit One World Trade shorter sessions. ruch student and a member of the college’s Center on Tuesday morning. Fichtel’s corner Some traders complained about longer board of trustees. office faced east, but from windows lining commuting times, the shortened trading During this time of dislocation, the FIA the eighth floor of the exchange’s corporate sessions, a lack of elbow room and tight se- provided a central communications point offices, he could see the devastation to the curity, but many were quick to compliment for the industry, collecting and distribut- tower and immediately made the decision to exchange officials for having the foresight ing contact details for displaced exchange evacuate the exchange’s three floors. eight years earlier to prepare for the worst. and clearing firm personnel. On Wednes- “I started yelling, telling everyone to get “It’s hot and loud but people are help- day, Sept. 12, the FIA began hosting con- out, and it was an orderly evacuation. I got ing each other out,” said Augustine Lauria, ference calls for member firms, exchanges, out of the building just in time to see the a trader with East Coast Options Services. and clearing organizations. More than 25 second plane hit Tower Two,” Fichtel said. Another major challenge was resolving calls took place over the subsequent six Two World Trade Center stood only steps what to do with trades made on the morn- days including Saturday and Sunday. At from Four World Trade Center, the home ing of Sept. 11 that had not been entered the peak, more than 80 people dialed in, of the exchange. into the clearing system. Nybot’s currency some with five or six people from their Nybot was the only exchange in New division, Finex, started trading in Dublin at firm on the call. Business, operations, York that had a backup trading floor. The 3:00 a.m. New York time and switched over technology and legal representatives par- idea for the backup came after the 1993 to the New York floor at 8:00 a.m. On Sept. ticipated from New York, Chicago and World Trade Center bombing and was 11, Finex contracts traded in New York for London. Some even participated from the spearheaded by Pat Gambaro, executive vice approximately 45 minutes. road as they struggled to get back to their president at the exchange. “Whatever trades were in the system offices in Chicago and New York. Calls Back in 1993, the exchange officials on the morning of the 11th we processed were scheduled twice daily and more fre- voted to put up $200,000 toward renova- Wednesday and generated clearing reports quently as needed. tion costs of what would become not only a for,” said George Haase, then president of New York Clearing Corporation. “As for Emotional Impact second-string trading floor, but also backup of the exchange’s computer system in lower the agricultural products, cocoa was only Reactions among the many people affected Manhattan. Nybot paid approximately open for 15 minutes and since many bro- by this disaster varied. A small number of $250,000 annually in rent. kers didn’t have their trading cards it was people in the futures industry stayed away “I guess you could say it was my baby,” too difficult to match up so all the trades from work because the emotional stress was Gambaro said while standing near the en- were deemed void.” too overwhelming. Most went back to their trance to the trading facility in Long Island offices, but many found it hard to concen- City less than two weeks after the devasta- Nybot’s Cramped New Home trate on their work and spoke of the “numb- tion. “We had to put up with finger point- Traders said the backup facility in Queens was ing” effect of the experience. ing from some people over the years saying crowded, noisy and difficult to reach, but they “We urged people to see grief coun- it was a waste of money. Unfortunately, we selors, because everyone was affected, had to use it, but fortunately we were pre- praised the exchange’s foresight in having the directly or indirectly,” said SMW’s Mar- pared.” space ready and available when the main trading kowitz. “We gave them time off, as much The “exchange” sat amid a row of ware- floor was destroyed in the Sept. 11 attacks on as they needed, but some people would houses in an industrial area of Queens, a the World Trade Center. rather be at work, with their friends and few subway stops to the east of midtown Photo courtesy of New York Board of Trade. a purpose, than at home just thinking Manhattan. Inside, the cramped trading about this stuff.” floor was dramatically different from the But even at the office it was difficult to pits that were destroyed. The new 3,000 escape the reminders of the disaster in the square foot trading area was one-quarter the news, in the daily round of funerals, and in size of the old floor and, with a low ceiling, the smoke that continued to rise from the the noise generated from open outcry was wreckage for weeks afterwards. And not just louder than usual. American flags lined the at work; several people told Futures Industry walls and makeshift booths were crammed that the disaster claimed familiar faces from with telephones and clerks. local churches, firehouses and school boards The backup facility only had two pits, in their neighborhoods. so the exchange set up a staggered trading

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Another problem that Nybot had to Nymex Gets Up and Running would have been done to the computers. wrestle with was that the September cur- Approximately four hours after the terrorist Meanwhile, new problems were surfac- rency futures contracts were due to expire attack, an emergency Nymex board meet- ing. To run the generators, Nymex needed Monday morning. Even under the best of ing was held via teleconference as exchange huge amounts of diesel and since the Ny- circumstances, the delivery cycle is a very officials quickly began to evaluate what was mex building was well within the cordoned complex, intensive process, and with the done and what needed to be done to get off area near Ground Zero, diesel trucks chain of contact between the banks, clear- back to trading. could not make deliveries. ing firms and the exchange disrupted by the “We sent people in the building around “We were engaging the White House, attacks, the potential for problems looked midnight including Richard Schaeffer our the governor’s office and the mayor’s office very high. treasurer, and national guard people, police just to get the fuel in. We were identified Nybot officials had extensive discus- officers and a senior vice president,” said as a critical asset in terms of national secu- sions with clearing firms on how to re- Robert (Bo) Collins, then president of Ny- rity. We were fairly high up on the White solve this issue, and together the two mex. “Getting to the building was difficult, House’s lists of priorities,” Collins said. sides came up with several solutions on but when they got inside it was virtually With traders, firms and even the White how to deal with the oncoming delivery unscathed.” House clamoring for Nymex to reopen its process. Backup diesel generators were turned on, energy and precious metals markets, the ex- “We talked to the CFTC and it but the city had cut water to the building. change began to plan how to get its markets was decided on Friday that any posi- Without water, the air conditioning system open again. Not long after the collapse of tions that remained open on Monday could not run and Collins said the tem- the World Trade Center, Chicago Mercan- in September currency would be auto- perature inside rose to around 105 degrees. tile Exchange president and chief executive matically rolled into the December con- Fortunately the city turned the water back officer Jim McNulty and CME chairman tract,” Haase said. on 30 minutes before permanent damage Scott Gordon called Nymex officials and offered to help in any way they could. A Nymex consultant drove through the night, with the dust from the collapse of the World Nymex Reopens Trade Center still on his clothes, to begin Nymex chairman Vincent Viola welcomes traders back to the building at a reopening ceremony on a discussion of listing Nymex products on Sept. 17 with the exchange’s president, J. Robert Collins, treasurer Richard Schaeffer, and its vice- Globex. The CME put together a team chairman Mitchell Steinhouse. Viola was flanked by Mayor Rudy Giuliani, Governor George Pataki, of more than 20 people and began work- Senator Hillary Rodham Clinton, and Representative Carolyn Maloney. Everyone who came to the ing around-the-clock to be ready if Nymex chose to go forward. Meanwhile, in New exchange that day was given a tee-shirt with an American flag on the front and the Nymex logo on York, the Nymex staff was working fever- the back. ishly to get the Internet version of its Access Photo courtesy of New York Mercantile Exchange. electronic trading system up and running. For months the exchange had been working on the system, preparing it for use over the Internet. But a number of glitches forced it to delay the rollout, and many firms doubted that the exchange could get the system up and running in such a short time frame. “On Thursday we pressed to get the mar- ket open. We were beta testing the system and we had a handful of technical issues we had to silence. Also, connectivity was a problem as we had to make sure all mem- bers had equal and fair access,” Collins said. By Friday afternoon, after an extraordi- nary, round-the-clock effort, the exchange had resolved most of the problems and be- gan live trading over the Internet. Although the trading session only lasted two hours, Nymex was the first exchange in New York to resume trading.

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Some firms were unable to connect to on Monday and lining up transportation to Around midnight, Collins started clean-up the system due to internal security issues, get thousands of traders past the military efforts with Vincent Viola, then chairman and had to scramble to be able to place checkpoints, through the destruction and of Nymex, and two contract facility people. trades, but managed thanks to the willing- to the pits. Luckily for Nymex, its building “We had about a two month supply of ness of other firms to share their access to had access to the Hudson River, and its of- paper towels and we sopped it up,” Collins the system. ficials were able to charter three ferries to said. “We were there until 7:00 the next Nearly 70,000 lots traded during two-hour bring traders and staff from docks in New morning cleaning.” session, well above expectations. Collins called Jersey, Manhattan and Long Island. Ini- that a “tremendous” volume, particularly tially, ferry was the primary transport to Chicago compared to the average volume of trading on the exchange. Some lines to board ferries to Exchanges Offer Help the old version of Access before Sept. 11, and the exchange were over an hour long in the Futures exchanges in New York weren’t the compared to any other electronic platform in weeks immediately after the disaster. only ones sent reeling following the terror- the physical commodity world. “My commute normally takes about an ist attack. The Chicago Board of Trade and For many in the futures industry, the mere hour and it took more than three hours the CME suffered a serious disruption of fact that Nymex reopened successfully on a from when I left my house until I reached trading on both Tuesday and Wednesday as new platform was an extraordinary achieve- the trading floor,” said John Dobrowski, a shortened trading schedules in some mar- ment. Under normal circumstances, it might local gold trader. “The security to get in was kets continued until Monday, Sept. 17. have taken months for the exchange to work intense; it’s like a fortress.” Eurodollars and bonds were open for a out all the bugs, connect all the users and run Before resuming open outcry trading on little while on Tuesday, Sept. 11 in Chicago. the necessary tests. Instead, under extraordi- Monday, Sept. 17, exchange officials had Most of the commodity markets at both nary pressures, the process was compressed to solve a last-minute crisis. Late on Sat- the CBOT and CME don’t open until af- down to just three days. urday night, one of the exchange’s genera- ter 10:00 a.m. EST, so those markets never One reason why Nymex officials were tors failed, causing a diesel spill on the 16th opened the morning of the attack. pushing so hard to get the exchange open floor, the mechanical floor of the exchange. Traders said there were some “wild” on Friday was that September gold options were set to expire that day. Although trad- ing on the Friday eAccess session was lim- ited to futures contracts, which meant that CME Shows the Colors people holding options positions could not U.S. flags dot the floor of the Chicago Mercantile Exchange as limited trading resumed on Sept. trade out of them, the Friday session at least 13. Both Chicago exchanges halted trading on Tuesday, Sept. 11 and Wednesday, Sept. 12 in gave traders a way to access the underlying response to the terrorist attacks. futures market and provided an intrinsic Photo courtesy of Thomson Reuters. price for the options. The only alternative would have been to delay the expiration by several days, a move that the exchange considered but rejected. Industry sources explained that options on futures are often used as part of a complex strategy involving a range of instruments in the cash and derivatives markets. Moving the expiration would not only affect the immedi- ate option, but also would disrupt any other position linked to that options position and change the structure of the entire strategy. The exchange also came under pressure from large energy traders eager to get back into the futures contracts, partly because of appre- hension about possible warfare in the Middle East, but also because some energy contracts in the over-the-counter market relied on Ny- mex for certain pricing benchmarks. After the mostly successful launch of eAccess, Nymex officials worked toward getting its building ready for open outcry

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moves in Eurodollars and bond trading on monitor the operational status and financial with other firms displaced from downtown. the Tuesday before those markets were shut condition of member firms. Rand Financial took up the offer, and down shortly after the disaster. The market The agency also worked with its fellow some of its traders temporarily set up shop settled back on Thursday after all markets in regulators to coordinate the market-open- in Fimat’s conference room. Numerous Chicago were closed on Wednesday. Both ing process, and shared its resources with other firms made similar offers of help to the CME and CBOT worked with govern- exchanges and firms that had lost important their stricken colleagues, an important ges- ment officials to coordinate the reopening documents. By the same token, the agency ture of support even for the firms that had of securities and treasury markets with the also received help from the industry, partic- enough space in their backup facilities. cash markets. ularly with respect to the disaster recovery When several firms were unable to log into Meanwhile, both the CME and CBOT process in New York the Internet version of Nymex’s electronic trad- offered the New York exchanges assistance. One of the many difficult situations that ing system on Friday, Fimat, Cargill and the The CME, in addition to offering to put arose for the CFTC came as the Nymex other firms agreed to give them access through Nymex products on Globex, sent clearing prepared to launch the Internet version their own connections so that they could execute personnel to firms who had lost or dislo- of its electronic trading system. Although trades when that market reopened. cated staff to help with the clearing process. the CFTC had done an extensive review Similar cooperation took place at the ex- The CBOT offered Nymex and Nybot the of the system prior to the disaster, it was change level. As Nybot began moving op- use of the nearly vacant MidAmerica Com- worried that the system had not been fully erations to its backup facility in Queens, it modity Exchange trading floor if necessary tested with live trading. Recognizing the urgently needed to reestablish connections to re-establish open outcry trading. Board importance of reopening this market, the to member firms. The Chicago exchanges of Trade Clearing Corporation opened CFTC let Nymex go ahead, but made sure stepped in, sharing e-mail addresses and its business resumption center on LaSalle that it could monitor the trading online. other crucial information on clearing firms. Street for firms who brought personnel in “From the time it went up, we were on the Several industry officials commented on a from New York. BOTCC offered clearing system, watching live trading,” a CFTC of- spirit of pragmatism and determination that capability to both New York exchanges and ficial said. prevailed during the crisis, particularly during also helped Nybot pass along information The agency took a similar approach to the first few days. One official compared it to its clearing members when their e-mail the problems encountered by Nybot. CFTC to a wartime environment, when people take system was down. officials said they sought to strike a balance risks and cut through normal procedures to get between maintaining the integrity of the things done because of the urgency of the situa- CFTC Aids Industry, markets and giving exchanges the freedom tion. Others said, however, they had deep con- New York Office Impacted to make very rapid decisions. The key to the cerns about the risks of going forward with so Unlike other market emergencies in the process was constant communication, with much uncertainty, but recognized the urgency past, the terrorist attacks on Sept. 11 had both sides freely exchanging information of reopening the markets. a direct, physical impact on the Com- at all levels. Indeed, the biggest headaches The recovery of the futures industry modity Futures Trading Commission. The came not from the CFTC, but rather the from the devastation of the Sept. 11 attacks CFTC’s New York offices were located in intense security around the World Trade is a testament to the unprecedented spirit One World Trade Center. Fortunately, all Center and local agencies unwilling to cut of camaraderie and cooperation that went 83 employees managed to get out of the through red tape despite the emergency na- into reopening the markets. It is the story of New York office before Two World Trade ture of the situation. long hours and true leadership, of tragic loss Center collapsed. “Reactions to this horrible tragedy exem- but also courage and determination. Above Before the agency found new quarters, plify not only the resilience of the U.S. fu- all, it is a testament to the amazing strength most of the displaced staff moved into tem- tures markets but also the strength and de- and resiliency of the futures markets, and porary office space generously provided by termination of the industry leadership and all the people who work in our industry. Burson-Marsteller, the communications the courage and tenacity of their staffs,” said ...... company. In addition, some of the CFTC’s Jim Newsome, who was acting chairman of Will Acworth is the editor of Futures Industry market surveillance staff moved into office the agency at the time of the attack. magazine and Robert Plummer is a freelance space provided by Nymex, another instance writer based in New York. of the unusual spirit of cooperation that Spirit of Cooperation arose in the wake of this crisis. Rather than taking advantage of the firms Recognizing the widespread disruption weakened by the disaster, the industry of- caused by the attacks, the agency provided fered to help them get back on their feet, timely relief from certain record-keeping re- sharing their resources and contributing quirements and extended certain reporting money, space and people to help the recov- deadlines. It asked the exchanges in their ery effort. For example, Fimat offered to capacity as self-regulatory organizations to share its office space in midtown Manhattan

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