Tag Archives: Gold price manipulation

Central bank gold at the Bank of England

In a recent article, “How many Good Delivery gold bars are in all the London Vaults?….including the Bank of England vaults“, I considered how much gold is actually in the London Gold Market, and highlighted how the amount of gold stored in the London wholesale market has fallen noticeably in recent years.

That article highlighted that the amount of gold stored in custody at the Bank of England (BoE) fell by 350 tonnes during the year to 28 February 2015, after also falling by 755 tonnes during the year to end of February 2014. Therefore, by 28 February 2015, there was, according to the BoE’s own statement, £140 billion or 5134.37 tonnes of gold in custody of the BoE, or in other words ~ 410,720 Good Delivery gold bars.

The article also reviewed snapshots of the total amount of gold stored in the London vaults at various recent points in time.

Firstly, a reference on the London Bullion Market Association (LBMA) web site for a date sometime before 2013 stated that there had been 9,000 tonnes of gold (i.e. 720,000 Good Delivery bars) stored in London with two-thirds of this amount, or 6,000 tonnes, stored in the Bank of England (about 482,000 bars), and 3,000 tonnes stored in London ex Bank of England vaults (238,000 bars). (Nick Laird of Sharelynx subsequently pointed out to me that the earliest reference to this 9,000 tonne figure was from a LBMA presentation from November 2011.)

Secondly, by early 2014, the LBMA web site stated that there were only 7,500 tonnes of gold in all London vaults, i.e. ~600,000 bars, and of this total, three-quarters or 5,625 tonnes were at in Bank of England, ~ 450,000 bars, and only one-quarter or 1,875 tonnes was stored at LBMA London gold vaults excluding the Bank of England’s gold vaults.

So, the entire London market including the Bank of England had lost 1,500 tonnes (120,000 bars) between 2011 and early 2014, with 375 tonnes less in the BoE and 1,125 tonnes less in the London market outside the BoE.

Finally, on 15 June 2015, the LBMA stated that “There are ~500,000 bars in the London vaults, worth a total of ~US$237 billion”. This ~ 500,000 bars equates to 6,256 tonnes. (On 15th June 2015, the morning LBMA Gold Price was set at $1178.25, which would make $237 billion worth of gold equal to 201.145 million ounces, which is 6,256 tonnes).

Therefore, another ~1,250 tonnes of gold (approximately 100,000 Good Delivery bars) departed from the London gold vaults compared to the early 2014 quotation of  7,500 tonnes of gold in the London vaults.

So overall, between the 9,000 tonnes quotation in 2011, and the 6,256 tonnes 2015 quotation, some 2,750 tonnes (~ 220,000 Good Delivery bars) disappeared from the London gold vaults. With 6,256 tonnes of gold stored in the entire London vault network in 2015, and with 5,134 tonnes of this at the Bank of England, that would leave 1,122 tonnes of gold in London outside the Bank of England vaults.

To reiterate, “the London gold vaults“, in addition to the Bank of England gold vaults, refer to the storage vaults of JP Morgan and HSBC Bank in the City of London, the vaults of Brinks, Malca Amit and Via Mat (Loomis) located near London Heathrow Airport, the vault of G4S in Park Royal, and the Barclays vault managed by Brinks.

Because the Bank of England reveals in its annual report each year the value of gold it has stored in custody for its customers (central banks, international official sector institutions, and LBMA member banks), then it is possible to compare 3 years of gold tonnage figures, namely the years 2011, 2014 and 2015, and then show within each year how much of this gold is stored at the Bank of England, and how much is stored in London but outside the Bank of England vaults.

Nick Laird of www.sharelynx.com / www.goldchartsrus.com has done exactly this in the following sets of fantastic charts which he has created to graphically capture the above London gold trends, and a lot more besides. These charts are just a subset of a suite of inter-related gold charts that Nick has created to address this critical subject in the London Gold Market.

LBMA and BoE Holdings AU 01

Although the Bank of England is not a LBMA member, the Bank of England gold vaults are a critical part of the LBMA gold vaulting and gold clearing system, and LBMA bullion banks maintain gold accounts with the Bank of England which facilitate, among other things, gold lending and gold swaps transactions with central banks. Hence the above and below charts are titled “LBMA Vaulted Gold in London”.

LBMA and BoE Holdings AU 02

My “How many Good Delivery gold bars are in all the London Vaults” article had also quantified that nearly all of this ~1,122 tonnes consists of gold from physical gold-backed ETFs which store their gold in the London vaults. (previously rounded up to 1,125 tonnes for ease of calculation).

I had included 5 gold ETFs in my previous analysis namely, SPDR Gold Trust (GLD), Shares Gold Trust (IAU), ETF Securities – ETFS Physical Gold ETF (PHAU & PHGP), ETF Securities – Gold Bullion Securities (GBS & GBSS), and Source Physical Gold ETC (P-ETC), and also some smaller holdings at BullionVault and GoldMoney. In total these ETFs and other holdings accounted for just over 1,000 tonnes of gold in the London market.

However, I had missed a few other gold ETFs which also store their gold in the London vaults. Nick Laird, whose Sharelynx website maintains up-to-date gold ETF data and gold holdings, took the initiative to fill in the missing ETF blanks and Nick re-calculated the more comprehensive ETF holdings figures for London, which worked out at an exact 1,116 tonnes of gold, astonishingly close to the implied figure represented by the 1,122 tonnes outside the Bank of England vaults.

The additional gold backed ETFs also included in Nick Laird’s wider catchment were Deutsche Bank db Physical Gold ETC and associated Deutsche ETFs, ABSA gold ETF (of South Africa), Merk Gold ETF, and some smaller holdings from Betashares and Standard Bank. The following chart from Sharelynx shows the full data for physically backed gold ETFs storing their gold in London:

LBMA vaults ETF gold in London AU 06

 

We then discussed an approach, in conjunction with Koos Jansen and Bron Suchecki, to identify known central bank gold stored in the Bank of England vaults by tallying up this storage data on a country level basis. So, for example, assuming 5,134 tonnes of gold stored at the Bank of England in early 2015, the aim would be to try to account for as much of this gold as possible using central bank sources.

As mentioned in the ‘How many gold bars‘ article, the Bank of England stated in 2014 that 72 central banks (including a few official sector financial organisations) held gold accounts with the Bank. It is not known if any of these gold accounts are inactive or whether any of these accounts have zero gold holdings. The LBMA stated in 2011 that “The Bank of England acts as gold custodian for about 100 customers, including central banks and international financial institutions, LBMA members and the UK government”. Therefore there could also be more than 25 LBMA member commercial banks with gold accounts at the Bank of England.

Some of the Bank of England 5,134 tonne total would therefore be gold held in LBMA member bank gold accounts at the Bank of England, for which data is not public. Likewise, a lot of central banks do not reveal where their gold is stored, let alone how much is stored in specific vaults such as at the Bank of England and Federal Reserve Bank of New York.

However, many central banks have more recently begun to provide some information on where they say their official reserve gold is stored. Other central banks have always been to some extent transparent. Overall, a variety of sources, where possible, can be used to source locational data regarding central bank gold storage locations. There will continue to be gaps however, since some central banks remain non-cooperative, even when asked directly about where they stored their gold.

Tallying this type of central bank gold storage data will probably be a work in progress. However, there has to be a cut-off point for doing a first pass through the data, and this is a first pass. As a group, the European central banks have been especially forthcoming with gold storage data, compared to even 3-4 years ago (except for Spain). For other central banks, I looked in various places such as their financial accounts, and I contacted some of them by email with varying degrees of success.  About half of the 72 central banks on the Bank of England’s list were identified, again, with varying degrees of accuracy.

The following fantastic chart by Nick Laird captures an overview of this Bank of England gold storage data. Essentially the chart shows that the banks listed hold, or have stated that they hold, the respective quantity listed, and in total the named banks could account for x tonnes gold stored at the bank of England. This is labelled ‘Known Gold‘. Given ‘Known Gold’, this leaves the residual as ‘Unknown Gold‘.

Bank of England vaulted gold AU 03

The remainder of this article explains the logic and the sources behind each country, and why that country appears on the list. When a central bank claims to have stored gold at the Bank of England, or the evidence suggests that, it does not necessarily mean that the gold in question is held in custody in a gold set aside account or that it is allocated in identifiable bars, or even that it is actually there. Many central banks engage in gold lending, or have done so in the last 15-20 years, and have at times, or permanently, transferred control of that gold to LBMA bullion banks.

Until all central banks come clean about what form their gold holdings are in, which will never happen, then the amount of central bank gold that’s encumbered by bullion banks or under claims, liens, loan agreements etc will not be apparent.

SWEDEN

Sweden holds 125.7 tonnes of gold, and 48.8%, or 61.4 tonnes are stored at the Bank of England.

Swedish Riksbank - distribution of gold reserves
Swedish Riksbank – distribution of gold reserves

 

FINLAND

Finland holds 49.035 tonnes of gold, and 51%, or 25 tonnes are stored at the Bank of England.

Bank of Finland - Distribution of gold reserves
Bank of Finland – distribution of gold reserves

 

GERMANY

Germany holds 3,384 tonnes of gold, and 12.9%, or 438 tonnes are stored at the Bank of England. The Bundesbank’s ongoing repatriation of gold from New York and Paris does not alter the amount of Bundesbank gold held at the Bank of England.

Deutsche Bundesbank - distribution of gold reserves
Deutsche Bundesbank – distribution of gold reserves

 

Austria

Austria hold 280 tonnes of gold, and 80%, or 224 tonnes are stored at the Bank of England.

Oesterreichische Nationalbank (OeNB) - distribution of gold reserves
Oesterreichische Nationalbank (OeNB) – distribution of gold reserves

 

 Switzerland

Switzerland holds 1,040 tonnes of gold, and approximately 20%, or 208 tonnes are stored at the Bank of England.

Swiss National Bank - distribution of gold reserves
Swiss National Bank – distribution of gold reserves

 

Portugal

Portugal holds 382.5 tonnes of gold (annual report 2014), and 48.7%, or 186.3 tonnes are stored at the Bank of England.

Banco de Portugal - distribution of gold reserves
Banco de Portugal – distribution of gold reserves

 

Denmark

The following commentary about Denmark’s gold contains some key points on understanding how to identify which countries store gold at the Bank of England.

As of August 2015, Danmarks Nationalbank (the Danish central bank) holds 65.5 tonnes of gold.

In August 2015, the Nationalbank said that:

“Most of Danmarks Nationalbank’s gold is stored at the Bank of England, where it has been since it was moved for safety reasons during the Cold War. In March 2014, Danmarks Nationalbank inspected its stock of gold in the Bank of England.”

However, an earlier Nationalbank publication in 1999 said that 94%, or 62.7 tonnes was stored at the Bank of England.

Danmarks Nationalbank - location of gold reserves
Danmarks Nationalbank – location of gold reserves

Therefore, the assumption here is that 62.7 tonnes of Danish gold is stored at the Bank of England.

Note the Danmarks Nationalbank’s assertion that in order for gold to be lent it has to be moved to the London, since London is the centre of the gold lending market.

In 1999 “Almost 99 per cent, or 93 per cent of the Nationalbank’s total gold stock, had been lent.” The same 1999 Danish central bank article also said that:

Denmark gold lending BoE

I have underlined the above sentence since it’s of critical importance to understanding that in gold lending, central bank gold lent to LBMA bullion banks at the Bank of England does not necessarily move out of the Bank of England vaults. Lent gold may or may not move out the door, depending on what the borrower plans to do with the borrowed gold.

It also means that the total gold in custody figure that the Bank of England reveals each year (for example £140 billion in February 2015), consists of:

a) central bank gold stored at the Bank of England

b) bullion bank gold stored at the Bank of England

c) central bank gold that has been lent or swapped with bullion banks (gold deposits and gold swaps) and that has not been moved out of the Bank of England vaults. This category of gold is still in custody at the Bank of England. The central bank claims to still own it, the bullion bank has control over it, and the Bank of England still counts it as being in its custody.

Netherlands

The Netherlands holds 612.5 tonnes of gold, and 18%, or 110 tonnes are stored at the Bank of England.

De Nederlandsche Bank (DNB) - distribution of gold reserves
De Nederlandsche Bank (DNB) – distribution of gold reserves

 

United Kingdom

The UK gold reserves are held by HM Treasury within the Exchange Equalisation Account (EEA). EEA gold reserves totals 310.3 tonnes, and all 310.3 tonnes are stored at the Bank of England.

UK HMT EEA

Notice that the UK gold reserves includes holdings of gold coin, as well as gold bars.

 

Ireland

Ireland hold 6 tonnes of gold in its official reserves, a small amount of which is in the form of gold coins, but nearly all of which is in the form of gold bars stored at the Bank of England.

CB 1 Ireland

Recently, I submitted a Freedom of information (FOI) request to the Central Bank of Ireland requesting information such as a weight list of Ireland’s gold stored at the Bank of England. After the FOI request was refused and the Central Bank of Ireland claimed there was no weight list, I appealed the refusal and was provided with a SWIFT ‘account statement’ from 2010 that the Bank of England had provided to the Central Bank of Ireland. See below:

Central Bank of Ireland - gold bars at the Bank of England
Central Bank of Ireland – gold bars at the Bank of England

This statement shows that as of 31 December 2010, the Central Bank of Ireland held 453 gold bars at the Bank of England with a total fine ounce content of 182,555.914 ounces, which equates to an average gold content of 402.993 fine ounces per bar. It also equates to 5.678 tonnes, which rounded up is 5.7 tonnes of gold stored at the Bank of England.

The fact that no weight list could be tracked down is highly suspicious, as is the fact that Ireland had in earlier years engaged in gold lending, so did not, at various times in the 2000s have all of its gold allocated in the Bank of England. How a central bank can claim to hold gold bars but at the same time cannot request a weight list of those same bars is illogical and suggests there is a lot more that the Central Bank of Ireland will not reveal.

 

Belgium

Belgium holds 227 tonnes of gold, most of which is stored at the Bank of England with smaller amounts held with the Bank of Canada and with the Bank for International Settlements. Banque Nationale de Belgique (aka Nationale Bank van België (NBB)) does not publish an exact breakdown of the percentage stored at each location, however, in March 2013 in the Belgian Parliament, the deputy Prime Minister and Minister for Finance gave the following response in answer to a question about the Belgian gold reserves:

Most of the gold reserves of the National Bank of Belgium (NBB) is indeed held with the Bank of England. A much smaller amount held with the Bank of Canada and the Bank for International Settlements. A very limited amount stored in the National Bank of Belgium.

Furthermore, there were a series of reports in late 2014 and early 2015 that would suggest that Belgium stores 200 tonnes of its gold at the Bank of England. Firstly, in December 2014, VTM-nieuws in Belgium reported that the NBB governor Luc Coene had said that the NBB was investigating repatriating all of its gold. See Koos Jansen article here.

On 4 February 2015, Belgian newspaper Het Nieuwsblad said that Belgium would repatriate 200 tonnes of gold from the Bank of England, but the next day on 5 February 2015, another Belgian newspaper De Tijd reported that NBB Luc Coene denied the repatriation report, and quoted him as saying:

There are other and more effective ways to verify if the gold in London is really ours. We have an audit committee that inspects the Belgian gold in the UK regularly”.

See another Koos Jansen article on the Belgian gold here.  However, Luc Coene did not deny the figure of 200 tonnes of Belgian gold stored in London.

Therefore, the assumption here, backed up by evidence, is that Belgium stores 200 tonnes of gold at the Bank of England.

 

Australia

Australia holds approximately 80 tonnes of gold in its official reserves, with 1 tonne on loan, and 99.9% of gold holdings stored at the Bank of England. See 2014 annual report, page 33.  According to a weight list of its gold held at the Bank of England, released via an FOIA request in 2014, Australia stores approximately 78.8 tonnes of gold at the Bank of England.

Reserve Bank of Australia

 

 South Korea

South Korea (Bank of Korea) holds 104.4 tonnes of gold, 100% of which, or 104.4 tonnes is stored at the Bank of England. The Bank confirmed this to me in an email on 11 September 2015. See email here ->

Bank of Korea (BOK) - location of gold reserves
Bank of Korea (BOK) – location of gold reserves

 

International Monetary Fund

The IMF currently claims to hold 2,814 tonnes of gold after apparently selling 403.3 tonnes over 2009 and 2010 (222 tonnes in ‘off-market transactions and 181.3 tonnes in ‘on-market transactions’). Prior to 2009, IMF gold holdings had been 3,217 tonnes, and had been essentially static at this figure since 1980 [In 1999 IMF undertook some accounting related gold sale transactions which where merely sale and buyback bookkeeping transactions].

Although the IMF no longer provide a breakdown of how much of its gold is stored in each location where it stores gold, the amount of gold held by the IMF at the Bank of England can be calculated by retracing IMF transactions from a time when the IMF did provide such details. In January 1976, the IMF held 898 tonnes of gold at the Bank of England in London, 3,341 tonnes at the Federal Reserve Bank of New York, 389 tonnes at the Banque de France in Paris, and 144 tonnes at the Reserve Bank of India in Nagpur, India. Therefore, of the IMF’s total 4,772 tonnes holdings at that time, 70% was stored in New York, 19% in London, 8% in Paris and 3% in India. See here and here.

In the late 1970s, the IMF sold 50 million ounces of gold via two methods, namely, 25 million ounces by ‘public’ auctions, and 25 million ounces by distributions to member countries.

In the four-year period between mid-1976 and mid-1980, the IMF sold 25 million ounces of gold to the commercial sector via 45 auctions. Thirty five of these auctions delivered gold at the FRBNY, 7 of these auctions delivered gold at the Bank of England, and 3 of the auctions delivered gold at the Banque de France.

Of the 7 auctions that delivered the IMF’s gold at the Bank of England, these auctions in total delivered 3.74 million ounces [Dec-76: 780,000 ozs, Aug-77: 525,000 ozs, Nov-77: 525,000 ozs, May-78: 525,000 ozs, Oct-78: 470,000 ozs, Mar-79: 470,000, and Dec 79:444,000 ozs], which is 116 tonnes. See IMF annual report 1980.

The IMF also sold 25 million ozs of gold to its member countries within four tranches over the 3 year period from January 1977 to early 1980. These sales, which were also called gold ‘distributions’ or ‘restitutions’ and covered between 112 and 127 member countries across the tranches, were initially quite complicated in the way they were structured since they involved IMF rules around quotas which necessitated the gold being transferred to creditor countries of the IMF and then transferred to the purchasing countries. In the later sales in 1979 and 1980 countries could purchase directly from the IMF.

Countries could choose where to receive their purchased gold, i.e. London, New York, Paris or Nagpur, however, the US, UK, France and India, which had the largest IMF quotas and hence the largest gold distributions, all had to receive their gold at the respective IMF depository in their own country. I don’t have the distribution figures to hand at the moment for the 25 million ozs sold to countries, but about 18 countries took delivery from the Banque de France in Paris, with the rest choosing delivery from New York and London.

Therefore an assumption is needed on the amount of gold the IMF ‘distributed’ to member countries from its Bank of England holdings between 1977 and 1980. Of the 25 million ounces distributed, the US received 5.734 million ozs, the UK received 2.396 million ozs (75 tonnes), France received 1.284 million ozs, and India received 805,000 ozs. Subtracting all of these from 25 million ozs leaves 14.78 million ozs which was distributed to the other ~120 countries. Since the IMF held 70% of its holdings at the FRBNY in 1976, 19% at the Bank of England and 8% at the Banque de France, apportioning these three weights to the remaining 14.78 million ozs would result in 10.76 million ozs (332 tonnes) being sold from the FRBNY, 2.867 million ozs (89 tonnes) from the Bank of England and 1.24 million ozs (38.5 tonnes) from the Banque de France.

Adding this 89 tonnes to the 75 tonnes received by the UK would be 164 tonnes distributed from the Bank of England IMF gold holdings. Add to this the 116 tonnes of London stored IMF gold sold in the auctions equals 280 tonnes. Subtracting this 280 tonnes from the IMF’s London holdings of 898 tonnes in January 1976 leaves 618 tonnes.

In 2009 the IMF said that it had sold 200 tonnes of gold to India, 2 tonnes to Mauritius, 10 tonnes to Sri Lanka,and then 10 tonnes to Bangladesh in 2010. The Bangladesh figures reflect its 10 tonne purchase. However, at the moment, there has been no exact confirmation that the 200 tonnes that India bought is in London. It probably is in London, but leaving this amount under the IMF holdings instead of in India’s holdings makes no difference. Subtracting the Bangladesh sale of 10 tonnes, and rounding down slightly, there are 600 tonnes of IMF gold (excluding the 2009 India 200 tonnes sale) stored at the Bank of England.

The IMF sales of gold to Sri Lanka and  Mauritius in 2009 of a combined total of 12 tonnes probably came out of the IMF’s London holdings also. The IMF’s sale of 181.3 tonnes of gold in 2010 via ‘on-market transactions’ may also have come out of the IMF’s London stored gold. These ‘on-market transactions” look to have used the BIS as pricing agent, and the IMF have gone to great lengths to hide the full details of these sales from public view. More about that in a future article.

 

India

The Reserve Bank of India holds 557.75 tonnes of gold. Of this total, a combined 265.49 tonnes are stored (outside India) at the Bank of England and with the Bank for International Settlements. In 2009 India purchased 200 tonnes of gold from the IMF via an ‘off-market transaction‘. A slide from this presentation sums up this information.

The questions then are, is the 200 tonne purchase from the IMF stored at the Bank of England, and how much of the earlier 65.49 tonnes is stored at the Bank of England.

Reserve Bank of India - gold held outside India
Reserve Bank of India – gold held outside India
A 2013 article in the Indian Business Standard which was reprinted from “Reserve Bank of India history series. Volume 4, 1981-1997, Part A”, explains that in 1991, the Reserve Bank of India entered 2 separate gold loan deals, one deal with UBS in Switzerland (which required 18.36 tonnes of RBI gold to be sent to Switzerland) and the other deal with the Bank of England and Bank of Japan (where 46.91 tonnes was required to be sent to the Bank of England). Together those 2 transactions equals 65.27 tonnes which is 0.222 tonnes short of the 65.49 total.
After the gold loan deals expired, it looks like 18.36 tonnes of Indian gold were left in Switzerland and transferred to safekeeping or deposit with the BIS, and 46.91 tonnes of Indian gold was left at the Bank of England.
Regarding India’s purchase of 200 tonnes of gold in 2009, the IMF only has gold 4 depositories, namely, the Bank of England, Federal Reserve Bank of New York, Banque de France, and the Reserve Bank of India in Nagpur, India. Given that the Indian gold stored abroad is “with the Bank of England and the Bank for International Settlements“, then for the 200 tonnes of IMF gold to end up being classified as ‘with’ the BIS, it would have to have either been transferred internally at one of the IMF depositories to a BIS account, or transferred via a location swap or a physical shipment to a BIS gold account at the vaults of the Swiss National Bank in Berne.
For now, the 200 tonnes of gold sold by the IMF to India in 2009 is reflected in the IMF holdings and not the India holdings. It does not make a difference to the calculations, since the 200 tonnes is still at the Bank of England.
Bulgaria
Bulgaria has 40.1 tonnes of official gold reserves. The latest BNB annual report states that 513,000 ozs are in standard gold form, and 775,000 ozs are in gold deposits.
Bulgaria CB
In 2014, about 60% of Bulgaria’s gold was in gold deposits. These deposits are ‘stored’ in the Bank of England. Therefore approximately 24 tonnes of Bulgaria’s gold is at the Bank of England.

Bulgaria 2

 

Bank for International Settlements

The Bank for International Settlements (BIS), headquartered in Basle, Switzerland does not have run any gold vaults of its own. However, the BIS is a big player in the global central bank gold market, and it offers its central bank clientele gold safekeeping (and settlement) services using central bank vaults in London, New York and Berne. These services are possible because the BIS maintains gold accounts at the Bank of England, the Federal Reserve Bank of New York, and the Swiss National Bank in Berne. BIS gold accounts can act like omnibus accounts in that many central banks can hold gold in sub-accounts under a BIS gold account at each of these institutions in London, New York and Berne.

Gold can then be transferred around locations using gold swaps where one of the counterparties to the gold swap is the BIS.

BIS gold services to the global central bank market
BIS gold services to the global central bank market

The BIS is involved with gold in 3 main categories.

a) the BIS holds gold in custody for customers, off of the BIS balance sheet

b) the BIS has its own gold holdings which are classified as its gold investment portfolio, and which are on its balance sheet

c) the BIS accepts gold deposits from central banks. These gold deposits appear as a liability on the BIS balance sheet. Then the BIS turns around and places these gold liabilities in the market under its own name. These placing are also in the form of gold deposits and gold loans with other institutions including commercial banks. These ‘assets’ are then classified on the BIS balance sheet as BIS’ “gold banking” assets.

a) In its latest annual report, as of the end of March 2015, the BIS stated that it holds 443 tonnes of gold under earmark for its central bank customers on a custody basis. This gold is not on the BIS balance sheet. i.e. it is ‘off-balance sheet’ gold held by the BIS.

Bank for International Settlements - Off-Balance sheet gold in custody for customers
Bank for International Settlements – Off-Balance sheet gold in custody for customers
b) The BIS also holds 108 tonnes of its own gold (on balance sheet within an investment portfolio). This BIS gold is either kept in custody or transferred to bullion banks as gold deposits. The BIS does not provide granular data in its annual report as to how much of its own gold is ever put into gold deposits.
BIS 108
c) As of 31 March 2015, the BIS had 510 tonnes of gold assets on its balance sheet. Of this total, 108 tonnes was the BIS’ own gold, leaving 403 tonnes as banking assets (i.e. customer gold . Of this same 510 tonnes total, 55 tonnes were classified as gold loans, so 457 tonnes were not gold loans. If all 55 tonnes of gold loans were from customer gold, this would leave 348 tonnes of customer backed gold banking assets. On the same date (31 March 2015), the BIS held 356 tonnes of gold deposits from customers (sight deposits and short-term deposits) on the liability side of its balance sheet which originate entirely from central banks depositing gold with the BIS in sight and term deposits.
The question then is how to reflect BIS gold storage holdings at the Bank of England. While most if not all gold deposit transactions between central banks/BIS and bullion banks take place in London, the data is not readily published.
It was therefore decided, in the spirit of being conservative, to make an assumption on the BIS gold, and only use BIS customer custody gold and BIS own gold as inputs, and because BIS has gold accounts with 3 vaults (London, NY and Berne), to then just divide by 3 and say that one-third of BIS own gold and one-third of BIS ‘central bank custody gold’ is in London This would be 183.66 tonnes, i.e. (108+443)/3.
Therefore, this model states that 183.66 tonnes of BIS gold is stored in the Bank of England. This is probably being very conservative, especially given that no on-balance gold deposited by BIS customers is reflected in this figure.

 

Venezuela

Venezuela holds 361 tonnes of gold. All the Venezuelan gold is held in Caracas in Venezuela at the Banco Central de Venezuela except 50 tonnes are still stored at the Bank of England for transactions such as the gold swap with Citibank. See my article “Venezuela’s Gold Reserves – Part 2: From Repatriation to Reactivation“.

 

Bangladesh

Bangladesh Bank (Central Bank of Bangladesh) holds 14 tonnes of gold, and 84.2%, or 11.8 tonnes are stored at the Bank of England.

Bangladesh Bank - distribution of gold reserves
Bangladesh Bank – distribution of gold reserves

In September 2010, the IMF sold 10 tonnes of gold to Bangladesh Bank, bringing total gold holdings up from 3.5 tonnes to 13.5 tonnes. The fact that this gold is stored at the Bank of England shows that the IMF sold this gold from its holdings that were stored at the Bank of England. (Note, Bangladesh has recently added some small amounts of domestic confiscated gold to its reserves).

 

Mexico

Mexico’s central bank, Banco de Mexico (Banxico) currently hold 122.1 tonnes of gold.  At the end of 2012, Mexican official gold reserves totalled 4,034,802 ounces (125 tonnes), of which only 194,539 ounces (6 tonnes) was in Mexico, and 119 tonnes abroad.

According to a response from Banxico to Mexican economist Guillermo Barba, 99% of Mexico’s gold stored abroad is at Bank of England. So that  is 117.8 tonnes of Mexico’s gold stored at the Bank of England.

With Banxico now holding 122 tonnes according to the World Gold Council, and not 125 tonnes, the assumption is that the 3 tonne reduction came from domestic holdings.

Banxico - location of gold reserves
Banxico – location of gold reserves

 

Poland

Poland holds 102.9 tonnes of gold in its reserves. Poland’s central bank (Narodowi Bank Polski (NBP)) published a guide to Poland’s gold in 2014 in which it confirmed that nearly all of its gold is at the Bank of England. See pages 86-90 of the guide.

“How much gold did Poland possess before 1998? Approximately 746,463 ounces, of which almost 721 thousand was invested in deposits in commercial banks. In turn, the gold kept in the country was mainly coins, gold bars and various types of gold “scrap” bought by NBP.” (page 86)

Before 1998, only 25,463 ozs of NBP gold was kept in Poland, and 721,000 ozs (22.43 tonnes) was deposited with bullion banks. Poland then bought 80 tonnes of gold in 1998, bringing its gold reserves up to nearly 103 tonnes. The purchase was done as follows:

“…we used the services of a bank which constantly carries out similar transactions. Next, we made a location swap and the whole of NBP’s foreign gold reserves were deposited onto our account in the Bank of England.” (page 88)

It is likely that the NBP is referring to the BIS as the bank which purchased the gold on behalf of Poland, and then transferred it from one of the BIS gold accounts at the Bank of England to the NBP gold account at the Bank of England.

So that is 102.9 tonnes stored at the Bank of England.

Note also that, the Polish central bank explains that “It can be assumed that the gold that has been placed on the market at any time is precisely the gold that is held by the central banks in London“. In other words, central banks that have places gold on deposit (lent it) have done so with gold that they have stored in the Bank of England. See the following screenshot:

Narodowi Bank Polski - location of gold reserves
Narodowi Bank Polski – location of gold reserves

Note 6.1 on page 136 of the 2013 NBP annual report states:

“Gold and gold receivables The item comprises gold stored at NBP and deposited in a foreign bank account. As at 31 December 2013, NBP held 3,308.9 thousand ounces of gold (102.9 tonnes).

The annual report is a large file and slow to downlaod so its probably not worth downlaoding it http://www.nbp.pl/en/publikacje/r_roczny/rocznik2013_en.pdf

This statement about the “gold stored at NBP and deposited in a foreign bank account” has been in a few of the recent NBP annual reports. In April 2013, before the NBP had published the guide to its gold, I asked the NBP by email, based on the statement, to  clarify if the gold held abroad is held in custody, for example at the Bank of England or FRBNY or held in time deposits with commercial banks?”

The NBP responded: “Narodowy Bank Polski does not make gold time deposits with commercial banks”.

This may be true if the NBP is using sight deposits, but the 2013 answer, like so many other central banks currently, avoided providing any real information to the question.

Given that nearly all NBP’s 102.9 tonnes of gold was in the Bank of England when the 80 tonnes purchase was made in 1998, the assumption here is that still is the case, and that for simplicity, 100 tonnes of Poland’s gold is at the Bank of England.

 

Romania

Romania has 103.7 tonnes of gold in its official reserves.

National Bank of Romania - distribution of gold reserves
National Bank of Romania – distribution of gold reserves

In percentage terms, as at 31 December 2014, 27% of Romania’s gold was in ‘standard form’ which presumably means Good Delivery Bars (400 oz bars), 14% in gold coins, and 59% in ‘Deposits’ abroad. (59% of 103.7 tonnes is 61.2 tonnes)

Looking at earlier financial accounts, and going back to 2005/2004, the Romanian central bank held gold deposits with bullion banks, and gold deposits at the Bank of England, and the percentage of he gold in each of the 3 categories was very similar to 2014, specifically, in 2005 it was 32% in gold bullion in standard form, 13% in gold coins,and 55% in gold deposits.

Note the gold deposits with Bank of Nova Scotia and Fortis Bank Bruxelles in 2005 and additionally with the same two banks and with Barclays and Morgan Stanley NY in 2004.

National Bank of Romania 2005

Since the percentage breakdown between Romania’s bullion bank deposits (59%), standard bars (27%) and coins (14%) hasn’t varied much since 2005, and was at a similar mix over various years that I checked such as 2011 and 2014, the conclusion is that Romania has had more than  50% of its gold on constant deposit since at least 2004 (i.e. the original allocated gold is long gone).

The 2005 annual report also states that there were 61 tonnes of Romanian gold stored at the Bank of England. Since Romania had just under 105 tonnes of gold in 2005, this 61 tonnes was referring to the gold deposits, which central banks, as illustrated in numerous other examples, continue to count as their gold even though it has been lent to bullion banks.

Romania therefore had or has 61 tonnes of gold stored at the bank of England.

Note also the reference to central vault, which probably refers to a vault in Bucharest.

 

Philippines

The Philippines hold 225 tonnes of gold in its official reserves. In November 2000, when the Bangko Sentral ng Pilipinas (BSP) held 225 tonnes of gold, it explained in a press release titled ‘Shipment of Gold Reserves‘ that it ended up storing 95% of its gold at the Bank of England due to the use of location swaps with a counterparty (probably the BIS) that took delivery of BSP gold, and transferred gold to the BSP account at the Bank of England.

Bangko Sentral Philippines - 95% gold at Bank of England
Bangko Sentral Philippines – 95% gold at Bank of England

Since 2000, the BSP gold reserves have risen, fallen, and risen again and now total 195 tonnes. Assuming the ‘95% of its gold’ storage arrangement is still in place, then the Philippines has 95% of 195 tonnes, or 185 tonnes stored at the Bank of England.

 

Greece

Greece claims to hold 112.6 tonnes of gold. In 2013, the Greek finance ministry on behalf of the Greek central bank stated that half of Greece’s gold reserves were ‘under custody’ of the Bank of Greece, and the other half was ‘under custody’ of the Federal Reserve Bank of New York (FRBNY), the Bank of England and (very vaguely) Switzerland. Who actually controls Greece’s gold reserves at this point in time is anybody’s guess.

Bank of Greece, locations of Greece's gold reserves
Bank of Greece, locations of Greece’s gold reserves

See my article from February 2015, titled “Spotlight on Greece’s Gold Reserves and Grexit” which explores Greece’s official gold reserves.

Given that the Federal Reserve Bank of New York was listed by the Greek MinFin as a foreign gold storage location ahead of the Bank of England, the assumption here is that of the 50% of Greece’s gold held abroad, the FRBNY holds more of this portion than the Bank of England. And so the assumption is that the Bank of England holds 40% of the foreign half, i.e. 20% of the total of Greece’s gold, with the FRBNY holding 50% of the foreign half. Taking 112 tonnes of gold as Greece’s total gold holding, 40% of this is 22.4 tonnes stored at the Bank of England. (Note, Greek gold reserves keep increasing incrementally each month by small amounts. As I am not sure what these increases relates to, a recent rounded figure of 112 tonnes has been chosen).

 

Italy

The Banca d’Italia holds 2.451.8 tonnes of gold. Although in 2014, the Banca d’Italia released a document in which it confirmed that some of this gold is held at the Bank of England, there is no evidence to suggest that Italy’s gold in London amounts to more than a few tonnes left over from 1960s transactions.

Bank of England gold set-aside ledgers show that in 1969 there were less than 1000 ‘Good Delivery’ gold bars in the Banca d’Italia gold account at the Bank of England, weighing less than 400,000 ozs in total. This is equal to about 12 tonnes. Most of the Italian gold at the Bank of England was flown back to Rome (and Milan) in the 1960s.

Since there is no public documentation that Banca d’Italia has ever engaged in gold lending (as far as I am aware), then there would be no need for Italy to keep a lot of gold at the Bank of England. Nearly all of Italy’s foreign held gold (over 1,200 tonnes) looks to be in New York (assuming it hasn’t been swapped or used as loan collateral). Italy could have engaged in non-public gold transactions from the Bank of England using gold location swaps from the FRBNY, or from Rome, but there is no evidence of this.

So, this model assumes 12 tonnes of Italian gold is stored at the Bank of England.

 

Brazil

Brazil hold 67.2 tonnes of gold reserves. In 2012, Banco Central do Brasil told me by email that all of its gold reserves were in the form of ‘fixed term gold deposits at commercial banks only’. Since the gold would be required to be stored at the Bank of England for these gold deposit transactions to take place, Brazil therefore holds 67.2 tonnes of gold at the Bank of England. See email below:

Banco Central do Brasil - gold deposits
Banco Central do Brasil – gold deposits
Ecuador
Banco Central del Ecuador conducted a 3 year gold swap with Goldman Sachs in June 2014 where it swapped 466,000 ozs for US dollar cash This swapped amount of gold has been factored into the World Gold Council data for Ecuador, and the Ecuadorian reserves dropped by 14.5 tonnes in Q2 2014. from 23.28 tonnes to 11.78 tonnes. This swapped amount of 14.5 tonnes is most probably stored at the Bank of England, since Goldman Sachs proposed a similar deal with Venezuela in 2014 where the gold was required to be at the Bank of England for the swap to be initiated.
Bolivia
Bolivia Central de Bolivia holds 42.5 tonnes of gold, all of which is permanently on deposit with bullion banks. The Bolivian Central Bank is very transparent in explaining where its gold is ‘invested’. Hence, it has (until recently) even provided in its financial accounts, the names of the bullion banks which happened to hold its ‘gold deposits’ and the amounts held by each bank.
Banco Central de Bolivia
Banco Central de Bolivia
A recent Banco Central de Bolivia report for 2014 is less revealing and only shows the country distribution of the gold deposits, with 39% in the UK and the rest in France. While this probably refers to the headquarters of the actual bullion banks in question, i.e. Natixis is French etc, it could mean the gold is being attributed to the Bank of England and the Banque de France, so, a conservative approach here is to attribute 39% of 42.5 tonnes to the Bank of England, i.e. 16.6 tonnes stored at the Bank of England.
Banco Central de Bolivia
Banco Central de Bolivia
Peru
Peru holds 34.7 tonnes of gold in its official reserves.
At the end of December 2013, Banco Central de Reserva del Peru held 552,191 ounces (17 tonnes) of gold coins which were stored in the Bank’s own vault, and 562,651 troy ounces of “good delivery” gold bars (17.5 tonnes) which were stored in banks abroad, of which 249,702 ounces were in custody and 312,949 ounces in the form of short-term interest bearing deposits. See 2013 annual report.
Since the gold bars are all ‘good delivery’ bars (which is not the case at the FRBNY), and since Peru has still recently been engaging in gold lending, then the evidence suggests that 17.5 tonnes of Peru’s gold is stored at the Bank of England.
Peru CB
Latvia

Latvia hold 6.62 tonnes of gold in its official reserves after joining the Euro on 1 January 2014 and after transferring just over 1 tonne of gold to the European Central Bank (ECB). All of Latvia’s gold is stored at the Bank of England, therefore Latvia stores 6.62 tonnes of gold at the Bank of England.

Before this transfer of gold to the ECB, Latvia had 248,706 ozs of gold, and it transferred 35,322 ozs to ECB, leaving 213,384 ozs.

Latvia CB

The latest annual report of the central bank of Latvia explains this transfer to the ECB.

Central Bank of Latvia - gold transfer to the ECB, 2014
Central Bank of Latvia – gold transfer to the ECB, 2014
European Central Bank
The ECB holds 504.8 tonnes of gold. This gold was transferred by the Euro members to the ECB at the launch of the Euro by 1 January 1999. All the ECB gold is de-centrally managed, meaning that it stays where it was when transferred and is still locally ‘managed’ by the bank which transferred that gold to the ECB. Some banks may have transferred gold stored at FRBNY in fulfillment of their requirement, some banks may have transferred gold at the BoE, and countries such as France and Italy may have transferred amounts which are still stored at Banque de France and Banca d’Italia etc. Some of the ECB gold, such as the smaller amount transferred by Latvia, is in the Bank of England. Other amounts of the ECB’s gold are most certainly also at the Bank of England in London.
It would be a separate project to track these transfers. The 1 tonne of Latvian gold transferred to the ECB at the start o 2014 was included in the figures here just as a placeholder, so as to acknowledge that ECB gold is at the Bank of England. Given that the Euro is a competing currency to the US Dollar, the ECB may have more gold than not stored in Europe and not at the Federal Reserve Bank of New York, since ECB gold would logically be safer not stored in the main Reserve Bank of a competing currency bloc.

 

Iceland

Iceland holds 2 tonnes of gold reserves (precisely 63,831.46 ozs). Although the Bank of Iceland says that its gold is stored at the Bank of England and in its own vault also, nearly all the gold is stored at the Bank of England.

In its 2014 annual report, the Bank of Iceland said that “The Bank resumed lending gold for investment purposes in June 2014“, and “The Bank loaned gold to foreign financial institutions during the year”.

CB Iceland

The Bank of Iceland lent 99.7% of its gold during 2014 because this is the percentage of the gold reserves which are not payable on demand, but are payable in less than 3 months. See below screenshot.

Central Bank of Iceland - gold deposits
Central Bank of Iceland – gold deposits

For the purposes of this exercise, Iceland stores 2 tonnes of gold at the Bank of England.

 

Ghana

Ghana’s central bank, the Bank of Ghana, holds 8.7 tonnes of gold in its official reserves (precisely 280,872.439 ozs). Of this total, 39.3%, or 3.42 tonnes is held at the Bank of England, with 27.5% at the Federal Reserve Bank of New York, and 29.5% with investment bank UBS. See 2014 annual report.

Interestingly, Ghana refers to its gold account at the Bank of England as a ‘gold set aside’ account, which is the correct name for a Bank of England gold custody account of allocated gold. Probably more interestingly is that most central banks do not use this ‘set aside’ term.

Bank of Ghana

 

Conclusion

A number of central banks refuse to confirm the location of their gold reserves. I will document this in a future posting. Some of the large holders undoubtedly hold quite a lot of gold at the Bank of England, as do a number of smaller holders. Countries that could fit into this category include Spain, France, Colombia, Lithuania, Sri Lanka, Mauritius, Pakistan, Egypt, Slovenia, Macedonia, Malaysia, Thailand and South Africa. In fact any central bank which has engaged in gold lending is a candidate for having some of its gold stored at the Bank of England.

Spanish people take note. Spain refused to say where its 281.6 tonnes of gold is stored, and Banco de España has the dubious record of being Europe’s least transparent bank as regards gold reserves storage locations. Maybe a project for Spanish journalists.

Banque de France keeps 9% of its 2,435 tonnes of gold reserves abroad, and has in the past engaged in gold lending. So this 9%, or 219 tonnes, is probably stored at the Bank of England.

The ECB and BIS  no doubt have more gold stored at the Bank of England than the figures currently reflect. This would also increase the ‘known gold’ total. Egypt is another country which has had a gold set aside account at the Bank of England so is in my view an obvious candidate for the list.

Adding to the known total is therefore a work in progress.

Six months on ICE – The LBMA Gold Price

It’s now been 6 months since the LBMA Gold Price auction, the much touted replacement to the London Gold Fixings, was launched on an ICE Benchmark Administration (IBA) platform on Friday 20 March 2015.

For anyone not au fait with the gold price auction, the LBMA Gold Price is a twice daily auction that produces the world’s most widely used gold price benchmark, which is then used as a daily pricing source in gold markets and gold products across the globe.

The 6 month anniversary of the LBMA Gold Price’s launch thus provides an opportune time to revisit a few unresolved and little-noticed aspects of this recently launched auction a.k.a. global benchmark.

 

Manipulative Behaviour and the FCA

From 1 April 2015, the LBMA Gold Price also became a ‘Regulated Benchmark’ of the UK’s Financial Conduct Authority (FCA) along with 6 other systemically important pricing benchmarks, namely, the LBMA Silver Price, ISDAFix, ICE Brent, WM/Reuters fx, Sonia, and Ronia. These 7 benchmarks join the infamously manipulated LIBOR in now being ‘Regulated Benchmarks’.

Manipulating or attempting to manipulate prices in a Regulated Benchmark is now a criminal offence under the Financial Services Act 2012.

Benchmark administrators and contributors must comply with the FCA’s ‘key requirements’ for a regulated benchmark which “include identifying potentially manipulative behaviour, controlling conflicts of interest, and implementing robust governance and oversight arrangements.

The specifics are set out in Chapter 8 of the FCA’s Market Conduct sourcebook (“MAR”), with the details on ‘identifying potentially manipulative behaviour’ covered in MAR 8.3.6 which says that a benchmark administrator must:

identify breaches of its practice standards and conduct that may involve manipulation, or attempted manipulation, of the specified benchmark it administers and provide to the oversight committee of the specified benchmark timely updates of suspected breaches of practice standards and attempted manipulation

and also:

notify the FCA and provide all relevant information where it suspects that, in relation to the specified benchmark it administers, there has been:

(a) a material breach of the benchmark administrator’s practice standards 

(b) conduct that may involve manipulation or attempted manipulation of the specified benchmark it administers; or

(c) collusion to manipulate or to attempt to manipulate the specified benchmark it administers.”

and furthermore that the arrangements and procedures referred to above:

“should include (but not be limited to):

(1) carrying out statistical analysis of benchmark submissions, using other relevant market data in order to identify irregularities in benchmark submissions; and

(2) an effective whistle-blowing procedure which allows any person on an anonymous basis to alert the benchmark administrator of conduct that may involve manipulation, or attempted manipulation, of the specified benchmark it administers.”

Section 91 of the UK Financial Services Act 2012 deems it a criminal offence to intentionally engage “in any course of conduct which creates a false or misleading impression as to the price or value of any investment” which creates “an impression may affect the setting of a relevant benchmark”.

 

Recent Manipulation of Auction Starting Price

All of these FCA  rules and the criminalisation of price manipulation offences sound very good in principle.

It is therefore expected that the ICE Benchmark Administration Gold Price Oversight Committee have been liaising with the FCA about the following developments in the LBMA Gold Price auction that occurred within the period between 20 March 2015 and end of May 2015, which were documented as agenda item 4, on page 2 of the ‘redacted’ minutes of the ICE Benchmark Administration Gold Price Oversight Committee held on 1 June 2015 in London:

“4. Findings since go-live: IBA shared with the Committee that:

 • IBA, and some direct participants, had observed the price of futures spiking during the minutes immediately before the afternoon gold auction starts.
IBA are now de-emphasising use of the futures as a related market to consider when determining the starting price .”

The fact that IBA has deemed it necessary to follow this course of action (i.e. de-emphasise the use of futures as a starting price determinant), and the fact that some entity or entities have been pushing around futures prices as a means of influencing the LBMA Gold Price starting price suggests that nothing has changed in the gold market since the introduction of the new auction, and that the same players who were actively manipulating the gold price back in 2012 are still doing so, despite this becoming a criminal offence under UK law.

Recall that on 23 May 2014 when the  FCA “fined Barclays £26 million for failings surrounding the London Gold Fixing“, in its ‘Final Notice’ explanation it included the following comments on futures prices influencing the fixing price during the protracted and manipulated afternoon fixing of 28 June 2012 :

4.12. At the start of the 28 June 2012 Gold Fixing at 3:00 p.m., the Chairman proposed an opening price of USD1,562.00. However, the proposed price quickly dropped to USD1,556.00, following a drop in the price of August COMEX Gold Futures (which was caused by significant selling in the August COMEX Gold Futures market, independent of Barclays and Mr Plunkett).

“4.18. …before the price was fixed, there were a number of further changes in the levels of buying and selling in the 28 June 2012 Gold Fixing, which coincided with an increase in the price of August COMEX Gold Futures.

4.19. As a result of these changes, the level of buying at USD1,558.50 exceeded the level of selling (155 buying/45 selling), and the proposed price was likely to move higher. Given that the price of August COMEX Gold Futures was trading around USD1,560.00 at this time, if the Chairman did move the proposed price in the 28 June 2012 Gold Fixing higher, it was likely to be to a similar price level (which was higher than the Barrier).”

You can read the entire FCA account of the saga of the 28 June 2012 afternoon fixing here, and think about the consequences and meaning of the IBA move to de-emphasis futures prices and what it signals.

HSBC Gold Vault pallet and gate in background

Publicly Available Procedures – Not!

Which brings us to the procedures for establishing the auction starting price and subsequent prices for each round of the auction. On 28 April 2015, the IBA LBMA Gold Price web page, under ‘Auction Process’, stated that:

“The chairperson sets the starting price and the price for each round based on publicly available procedures.

 I was interested in reading these publicly available procedures, and learning about the price sources and price hierarchies used within the set of price determinants,  so on 28 April 2015, I emailed the IBA communication group and asked:

“I have a question on the LBMA Gold Price methodology.
 
On the IBA LBMA Gold Price web page (https://www.theice.com/iba/lbma-gold-price) under ‘Auction Process’, point 1 states that “The chairperson sets the starting price and the price for each round based on publicly available procedures“.
 
Can you direct me to where these ‘publicly available procedures’ are view-able?
 

Incredibly, IBA received my email that day, and then changed point 1 under ‘Auction Process’ by deleting the original reference to ‘publicly available procedures’ and by copying and pasting in the FAQ answer that I had referred to about ‘in line with current conditions and activity in the auction.

IBA then responded to my email on the same day, 28 April, without answering the question. The IBA response was:

Please note the updated text: ‘The chairperson sets the starting price and the price for each round in line with current market conditions and the activity in the auction’. Thank you for pointing this out.

So, not only did IBA avoid explaining the ‘publicly available procedures‘,  they also covered it up and had the cheek to thank me for pointing it out to them. You can see for yourself the reactionary and firefighting tactics used by IBA in perpetuating non-transparency.

Furthermore, the fact that the original web page said that the procedures were publicly available and then they pulled it suggests that at least someone with responsibility in IBA, maybe naively, originally had been of the view that the pricing procedures were to be publicly available.

I emailed IBA again and said:

“This FAQ answer (to the question “How are the prices set for each round of the auction?) doesn’t really explain anything at all.

My question though is, apart from this one line FAQ answer, are there no more in depth ‘publicly available procedures’ available that explain how the opening price is set, what the price sources used are, what pricing hierarchy is used to select an opening price etc..?”

I’ve looked on your web site and in the FAQs and can’t find them. The only brief reference to price determination in the FAQs is that the chairperson”sets the price in line with current market conditions and activity in the auction.”

To which IBA replied:

This information is not available on our website. However, as you seem to have a few questions, would you be interested in me setting up an off the record briefing with IBA in the next few weeks?”

I did not take IBA up on that offer since I do not think that an off the record briefing is appropriate for something that should be in the public domain. It also highlights the extent to which the vast majority of the financial media are happy to use unidentified sources, off the record briefings, and quotes, and willingly act as the mouthpieces for entities that they are too scared of offending lest they will not get ‘access’ to write their next regurgitated press release for, nor get invited to that entity’s Christmas party.

Next we come to the Chairpersons.

 

Chairpersons Я‘Us

According to a Reuters article on 19 March about the new auction:

“‘Four ex-bankers have been appointed as chairs and will rotate in their duty in the initial six months‘, one source said.”

And who are these four ex-bankers? Well, that is the billion dollar question, because, as Bulliondesk reported on 19 March in its article titled “ICE will not disclose names of chairs in new gold benchmark process“, after attending a press briefing with ICE:

“‘The names of those selected to oversee ICE’s new gold price benchmarking process will not be disclosed, Finbarr Hutcheson, president of ICE Benchmark Administration (IBA), said.

We are keeping that anonymous – we don’t think that it’s meaningful to the marketplace to know who’s running that auction and, frankly, the more we kind of feed the story, there’s just going to be more speculation around that,” he said at a briefing at its offices here.

There’s a legitimate desire to know but actually we don’t want this process to focus on any individual or names of people,” he added.

Not “meaningful to the marketplace to know who’s running the auction“? What sort of statement is that in a free market? If there is a legitimate desire to know, as Hutcheson concedes there is, then why hide the identities?

If anyone needs reminding, the predecessor to the LBMA Gold Price auction was a trading process which, on 23 May 2014, the UK Financial Conduct Authority (FCA) saw fit to fine Barclays £26 million “for failings surrounding the London Gold Fixing.” This was also the first and only precious metals trading process in the UK ever to receive a fine from the FCA.

I would suggest that given the history of a ‘proven to have been manipulated daily gold price auction’, whose successor on launch day primarily consisted of the 4 incumbent participants that comprised the previous Gold Fixings auction (including Barclays), then it certainly is meaningful to the marketplace to know who’s running the new auction.

Bulliondesk continued:

“’We have a panel of chairpeople that we are going to use and we have internal expertise as well on that, but we are not disclosing the names of those chairmen,’ Hutcheson said. “It will rotate through the panel but we have a significant bench of available external expertise with back-up if you like.”

Hutcheson declined to name how many chairpeople are on the panel.

But if the oversight committee were to feel that it was appropriate for the names to be disclosed, this stance may change, he suggested.”

And why would the oversight committee feel it to be appropriate or not to divulge the names of the chairpersons of the most important gold pricing benchmark in the world?

J119 and J120

The Changing of the Guard

Its interesting to see how ICE Benchmark Administration’s description of the chairpersons evolved over a short period after the LBMA Gold Price auction was launched on 20 March.

This was the initial version of the ICE IBA web site description of the Chairperson on 20 March (see screenshot 1 below also):

“The chairperson has extensive experience in the gold market, and is appointed by IBA, and therefore independent of the auction process.”

A week later, a revised, more lengthy version of the Chairperson description had appeared on the ICE IBA web site (see screenshot 2 below also):

“The Chair is appointed by IBA and is independent of any firm associated with the auction, including direct participants. The chair is externally sourced, but works with the IBA team to deliver a robust process for determination of the LBMA Gold Price.”

The Chair facilitates the determination of the LBMA Gold Price by providing his extensive market experience to assist in setting the price in each round of an IBA gold auction.”

By July, the second paragraph of the second version above had been changed to read:

“Both the initial and subsequent round prices are selected by the Chair using their extensive market experience and applied based on an agreed pricing framework.”

So, there is a panel of chairpeople, as Hutcheson told Bulliondesk, who are 4 ‘ex-bankers’ according to Reuters, and who have ‘extensive experience in the gold market’ according to the IBA web site. So these people were previously bankers (which means investment bank staff) who gained their experience of the gold market in investment banks, and who have extensive knowledge of how a gold auction works, and since they are working with London-based IBA on a London-based daily auction, the chairpersons are either London-based or live proximate to London. And finally, according to one of the web site versions above, it’s a ‘He’ or set of ‘Hes’ so we know they are male.

And yet these same people are said to be “independent of any firm associated with the auction, including direct participants.”

Given that there are now 11 direct participants in the LBMA Gold Price auction, namely,  Barclays, Bank of China, Goldman Sachs, HSBC Bank USA, JPMorgan Chase Bank, Morgan Stanley, Societe Generale, Bank of Nova Scotia – ScotiaMocatta, Toronto-Dominion Bank, Standard Chartered and UBS, how could ex-bankers based in London with extensive experience of the gold market collectively be independent of all of these banks?

And that’s just the direct participants. What about all the firms associated with the auction, for example, indirect participants who route their auction orders via direct participants?

It would be interesting to hear what IBA and the LBMA define as ‘independent’. Is there any precedent on a definition of ‘independent’ for persons connected to a daily gold auction? Luckily, there is.

A number of policy documents were drawn up and introduced for the previous London gold price auction, the London Gold Fixing, in approximately mid 2014. One of these documents was a “Terms of Reference for a Supervisory Committee of the Board of the London Gold Market Fixing Limited (LPMCL)“. That document describes the composition of a supervisory committee and deems that the  Board of directors of LPMCL may:

“appoint up to two independent qualified individuals to serve on the Committee. A person will be considered to be independent for the purposes of these Terms of Reference if he/she is not, and has not been at any time in the preceding year, an employee or consultant of any Member and does not otherwise have a personal interest in the fixing price or the Fixing Process.”

While this document was referring to a committee whose Members were the directors of the banks running the former auction, at least there is some semblance of a definition of the concept of ‘independent‘ when applied to a gold auction.

So using that yardstick, it would be interesting to measure up the ex-banker chairpersons in the current auction as to how long exactly have they and their handler have been ‘ex’ bankers. Less than a calendar year before 20 March 2015 (i.e. 01 January 2014) would not cut it under a  “has not been at any time in the preceding year, an employee or consultant of any Membertest.

And it also begs the question, why is the automated algorithm alluded to by ICE not being used in this LBMA Gold Price auction instead of a human chairperson?

 Chairperson description 1

19 March

 

 Chairperson description 2

26 March

 

Chairperson description version 3 

chairperson v3

 The Algorithm

You will notice from the first description screenshot of the chairperson (above) that on 20 March 2015, ICE IBA stated that:

“Feedback from the market is that the price in the first round of the auction, as well as the prices for the following rounds, is of paramount importance.

As a result, BA has appointed a chairperson from Day 1. In due course, IBA will evaluate developing an algorithm in consultation with the market.

Then notice that in the second version screenshot about the chairperson, there is no mention of any algorithm. It just vanished.

A slightly different version of the algorithm text appeared in the IBA gold price FAQ document published at launch time:

“Why are you using a Chairperson and not an algorithm for day one?

Feedback from the market is that the setting of the initial price of the first round of the auction, as well as prices for the following rounds, are important. As a result, it is appropriate to have a Chairperson on day one. In due course, IBA will consult on automating the auction process using an automated algorithm.”

A point of information at this juncture. When IBA and LBMA refer to ‘the Market’ they are referring exclusively to LBMA members of the wholesale gold market and not to any of the other hundreds of thousands of global gold market participants who rely on the LBMA Gold Price benchmark as a pricing source. In fact it seems that ‘the Market’ means whatever the LBMA Management Committee decide it means.

It is also worth pointing out that many of the LBMA’s claims on consulting ‘the Market’ are just empty rhetoric, and the consultations are purely for window dressing for decisions that they have already decided on, a case in point being the EY bullion market review commissioned by the LBMA  earlier this year that was announced on 27 April and wrapped up by June 2015. This is not too dissimilar to the way FIFA operates, as one correspondent pointed out.

In the case of the above ‘feedback from the market’ about wanting a chairperson, this could very well mean the 4 members of London Gold Market Fixing Limited (LGMFL) who all transitioned from the old auction to the new auction as if nothing had changed. It appears that they did not want anything to change. The old London Gold Fixing with 4 members had a chairperson (most recently Simon Weeks from Scotia) who rotated annually through the directors of (LGMFL), i.e. from Barclays, Scotia Mocatta, HSBC and SocGen.

Finbarr Hutcheson had also referred to this price calculation  ‘Algorithm’ on 19 March, the day before the LBMA Gold Price launch. To quote Bulliondesk again:

“The panel of the independent chairs will be responsible for overseeing the process although ICE has indicated that it will be looking to make the process electronic in future.

 

The LBMA Silver Price Algorithm

The LBMA Silver Price auction has a separate administrator, Thomson Reuters and a separate platform provider, CME Group.  Thomson Reuters has this to say about the opening price on page 8 of its LBMA Silver Price methodology guide:

3.7 Starting Price

The auction platform operator (CME Benchmark Europe Ltd) is responsible for operating the LBMA Silver Price auction, including entering the initial auction price.

The initial auction price value is determined by the auction platform operator by comparing multiple Market Data sources prior to the auction opening to form a consensus price based on the individual sources of Market Data. The auction platform operator enters the initial auction price before the first round of the auction begins….

For intra-auction prices for each round, the methodology guide says that:

3.8 Manual Price Override

In exceptional circumstances, CME Benchmark Europe Ltd can overrule the automated new price of the next auction round in cases when more significant or finer changes are required. When doing so, the auction platform operator will refer to a composition of live Market Data sources while the auction is in progress.

In the LBMA Silver Price methodology, only the first round is manually input. Subsequent rounds are calculated automatically by the ‘platform’. See page 7 of the guide:

“3.4 End of Round Comparison

[bullet point 2] If the difference between the total buy and sell quantity is greater than the tolerance value, the auction platform determines that the auction is not balanced, automatically cancels orders entered in the auction round by all participants, calculates a new price, and starts a new round with the new price.”

So this is different to the LBMA Gold Price where:

“The chairperson sets the starting price and the price for each round in line with current market conditions and the activity in the auction.”

 

Conclusion

Six months after the fanfare launch on 20 March 2015, unanswered questions remain:

  • How robust is the LBMA Gold Price auction mechanism, when within 3 months of launch date, IBA have to tinker with the price sources used to determine the starting price, and de-emphasise one price source due to volatile and seemingly delibrately manipulative futures price movements?
  • Why does the LBMA Gold Price auction needs a human chairperson throughout the auction and the LBMA Silver Price does not?
  • What happened to the plans for introducing an algorithm into the auction?
  • Why have ICE gone to great lengths to prevent the public knowing the identities of the chairpersons?
  • Why did ICE backtrack on a reference to ‘publicly available procedures‘ that would have explained how the starting price and round prices are determined?
  • What’s going to happen when the initial six months of the chairpersons’ rotating duties run out on Monday 21 September, as Reuters alluded to back in March?

ICE ICE

To that list some further questions could be added:

  • Where are the Chinese banks ICBC and China Construction, Bank which both expressed interest in becoming direct participants in the LBMA Gold Price auction, going to join?
  • Where are all the gold mining and gold refining entities that have expressed interest in being direct participants going to join, participants that the ICE auction platform can accommodate right now?
  • When will the LBMA Gold Price auction move to central clearing on an exchange distinct from LMPCL’s monopoly on clearing predominantly unallocated metal?
  • When will the prohibitive credit lines enforced by the LBMA be removed as as to allow other non-bank participants to directly participate in the auction without maintaining credit arrangements with the incumbent bullion banks?

These are just some of the questions which financial journalists cannot bring themselves to write about when covering this topic.

The pre-2015 London Gold Fixings – More technologically advanced than reported

The financial media has recently pitched the transition of the London daily gold fixings to an ICE Benchmark Administration (IBA) platform as a quantum leap from an antiquated Victorian-era process to a futuristic 21st century electronic auction.

For example, the Wall Street Journal recently said that:

“Four of the banks…had participated in the conference call used to determine the daily fixes, a system largely unchanged for nearly a centuryand that “Gold is the last of the precious metals to make the switch to an electronic platform.”

The evidence suggests however, that in the last decade, the technology utilised in the daily gold fixings was far more advanced than the media commentaries imply, and that since 2004, the old gold fixing was not as technologically backward as is generally accepted.

new court

Rothschild Departs, Barclays Joins – 2004

In April 2004, NM Rothschild announced that it was pulling out of commodity and gold trading, and also stepping down from chairing and participating in the twice daily London Gold Fixings. This left four banks as members of the fixing process, namely HSBC, Deutsche Bank, Scotia Mocatta, and SocGen.

According to Risk.net at the time, “the withdrawal of NM Rothschild from the market forced the London Gold Market Fixing company to introduce new fixing arrangements.

From a practical standpoint, with NM Rothschild no longer part of the fixings after May 2004, the meetings could no longer use Rothschild’s offices in St Swithins Lane near the Bank of England. Another practical point was related to the location of the remaining participants’ offices.

Since Barclays Capital, who took over the fixing seat from Rothschild, was based in Canary Wharf (15-20 minutes train ride east of Bank), the five fixing members were not all located in walking distance of a central physical meeting place in the City of London. Scotia’s and Deutsche’s offices were in the City, but another gold fixing member, HSBC, had also fully moved to Canary Wharf circa 2003. Round trip travel from Canary Wharf to Bank twice a day, or vice versa, would have been prohibitive on all but a temporary basis.

Web-Based Commentary

Rothschild’s departure precipitated discussion of three changes to the Fixings process, specifically, 1) an annually rotating chairperson, 2) a conference call, and 3) a far less well-known, ‘web-based commentary’.

On 29th April 2004, Tim Wood of Mineweb.com wrote an article titled “London Gold Fixing Ritual to End”. The article explained the three changes and referred to the web-based commentary:

“As expected, the London Gold Fixing has announced that it will in future rotate the chairmanship of the arrangement and end a tradition of meeting in person to set bellwether gold prices twice a day.

Starting in May, each member bank will assume the chairmanship of the fixing for a one year period starting with ScotiaBank division ScotiaMocatta.

As of the same date, the Fixing will take place by telephone and the five member firms will no longer meet face-to-face as has previously been the case. As part of this change, it is intended that a web-based commentary of the Fixing will be introduced later this year“, the Fixing said in a statement.

The decision by N.M. Rothschild & Sons to quit the gold business leaves a vacancy at the Fixing. Ongoing members are Deutsche Bank, HSBC, and Société Generale.

Simon Weeks is the chairman-elect of the London Gold Fixing.”

[Coincidentally, Tim Wood, currently executive director of Denver Gold Group, has now ended up sitting on the new 2015 LBMA Gold Price Oversight Committee with Simon Weeks, nearly 11 years after the above article was written.]

On 5th May 2004, the twice daily Gold Fixings transitioned from physically attended meetings at Rothschild’s offices to remote conference calls with Scotia as the new chair.

New York Times: Live web-based commentary

The New York Times, in a 6th May 2004 article titled “Pricing Gold but No Longer Standing on British Tradition” mentions a live” web-based commentary for the daily fixings:

“The London Bullion Market Association, which controls the price-setting process, plans to introduce a live Web-based commentary on the daily price-setting this year.”

‘Nothing was that much different apart from the fact that we didn’t walk down to St. Swithins Lane,’ said Simon Weeks, director of precious metals and foreign exchange at ScotiaMocatta, a unit of the Bank of Nova Scotia.”

(Note: The NY Times meant LGMFL, not LBMA, but they may have got confused because Simon Weeks was chairman of the LBMA at that time, as well as being chairman of the Gold Fixing company LGMFL).

Barclays then completed the purchase of Rothschild’s gold fixing seat in May 2004 (Risk.net 26th May 2004). In its article, Risk.net also confirmed the planned web-based commentary:

“LGMF (London Gold Market Fixing) said it intends to introduce web-based commentary of the fixing later this year.”

Barclays then joined the fixings on 7th June 2004.

Bank of England refers to a Web-based application

The most authoritative confirmation of this “web-based feature commentary” comes from the May 2004 edition of the Bank of England Quarterly Bulletin which was kept in the gold fixings loop as per usual, and saw fit to review and report on the changes taking place in the Gold Fixing. See page 14 of pdf where it states:

“Since 5 May, a telephone conference call has replaced the twice-daily physical meetings. A web-based application to allow viewing of the fixing process is to be introduced later in 2004.

Bank of England Quarterly Bulletin screenshot, May 2004:

BoE web based fixing app
Fast forward to 2014, and a publication titled “Financial Markets and the ACI Dealing Certificate 310-102“, by Philip J L Parker (ISBN 978-1-291-50352-4) also mentions this web-based commentary for the Fixing, stating:

“With effect from May 2004, the traditional face-to-face meetings (previously at the offices of NM Rothschild and Son), were replaced by a telephone fixing procedure. As part of this change, a web-based commentary of the Fixing has been introduced.

(Page 208: London Gold Fixing)

The above publication (published in August 2014) is a training manual for the ACI Dealing Certificate foreign exchange and money markets examinations, which are offered by the wholesale financial market association ACI (now called ACI – The Financial Markets Association). The first edition of this manual was published in 2013.

2014, page 208:

ACI Dealing - gold fixing - web-based commentary

So it appears that a live web-based commentary / web-based application has been used by the five members of the London Gold Fixing since 2004 that allowed the viewing of the fixing process, which would presumably mean viewing the orders entered by each participant and the intra-auction prices. However the existence of such as web-based application is never mentioned by the financial media, who persist in only ever mentioning a conference call, often in conjunction with the words ‘tradition’, ‘antiquated’ or ‘unchanging since 1919′ etc.

Pens and Paper?

It stands to reason that a live web-based application would be introduced and used during a conference call of the daily Gold Fixings. Given that the trader participants were located remotely from each other, it would be essential for the traders at each of the five firms to be able to see prices and current orders on their desktop screens during the fixings, and also essential for final order data to be captured in a trade capture system, then matched, and then sent downstream within trade, clearing and settlement processing systems.

As well as using phones, everything an investment bank trader or an inter-dealer broker does involves using one of their, often, six or more screens as input and output devices. They do not just use ‘bits of paper’ to record orders and trades and then pass these bits of paper to some junior person to run around the precious metals trading desk with. Trading screens are always used in conjunction with phones. Every order has to be captured and displayed, as well as calculated and processed in trade and settlement processing systems and downstream P&L and reporting systems.

We are talking here about order entry, trade execution, trade capture, trade processing, and trade clearing and settlement. We are also talking here about the most sophisticated investment banks on the planet, with the largest and most cutting edge technological and financial resources in any industry. We are talking about HSBC, ScotiaBank, Deutsche Bank, Barclays and Société Générale, not about two-bit bucket shops.

Until August 2014, the daily Silver Fixings comprised three of the same members as the daily Gold Fixings, namely HSBC, ScotiaMocatta and Deutsche. Given that both gold and silver trading would be run from the same precious metals trading desks in these banks,  it seems reasonable to suggest that any technological order capture and display systems that were being used in the gold fixings, would also be used in the silver fixings.

It therefore makes the following claim from Harriet Hunnable of the CME Group hard to fathom when she commented last October on how the CME had taken the Silver Fixings out of the dark ages (CME ‘proud’ of silver fix system):

“In a very short time, we’ve taken a market that was doing this on pen and paper on the telephone to an electronic platform.”

I find this ‘pen and paper’ reference extremely hard to believe given the discussion of a web-based application in the Gold Fixings since 2004. Financial media commentaries at the time, in August 2014, also stuck to the dark ages script with CNBC headlining its coverage as “Victorian-era silver fix joins electronic age“.

Note that even ‘voice-brokered trades’ done by the large inter-dealer brokers such as ICAP and Tullet Prebon make use of screens as well as phones. Screens are intrinsic to all modern voice trading, as are messaging apps, and chat apps (although messaging and chat apps will probably be more highly regulated and  subject to stricter compliance controls going forward).

It would be naive of anyone to think that daily Gold Fixings involving five distinct dealing rooms of five huge investment banks were not using various forms of order entry, trade capture, and various types of networked technology, to keep track of gold and silver fixing prices and orders and to visually display this updated data on traders’ screens and desktops during the daily fixing auctions.

Furthermore, the resulting net order data would have to be passed to other trade processing systems for downstream processing into London Precious Metals Clearing Ltd’s (LPMCL) metal clearing AURUM system, for netting and clearing and settlement, while the price and time-stamp data would need to be passed to price data vendors for distribution as well as to the LGMFL goldfixing.com web site.

Trading floor screens

Without a functional specification document, its hard to know what the original specification of a 2004 web-based commentary/web-based application used on the five trading floors would have entailed, and whether it would be originally designed and built in-house by one or a number of the technology departments of the five fixing member banks, or whether this type of project would have been outsourced. But trading floor technology is always changing and evolving and indeed, trading technology did change rapidly from 2004 to 2014.

Applications designed and used within investment banks do not stay static and they also have to be supported and maintained. Applications either evolve with the evolution of an investment bank’s technology environment or they are decommissioned and replaced. So it’s doubtful if a web-based app created in 2004-05 would still exist in its original version 1.0 form in 2014-15.

Goldfixing.com

Examining the observable technology connected to the London Gold Market Fixing Company also brings up some interesting information. One window into the London Gold Market Fixing Ltd was its website www.goldfixing.com. The domain lookup for the www.goldfixing.com provides both registrant and technical support information.

The site was registered on 22nd December 1999 by  Emilie Rivoire of NM Rothschild (emilie.rivoire@rothschild.co.uk). This would make sense since NM Rothschild was the permanent chair of the daily gold fixings until 2004. The first version of the goldfixing.com website was created by a South African company called Catics Ltd in 2000.

Gold Fixing Rothschild Hackwood

As Catics stated in their scope for the brief of the Rothschild gold fixing website:

“Rothschild, with approval from the other 4 members, approached us to design an elegant new web site. The site was created as a quick up-to-date historic guide about the London Goldfix. All interested parties can see how the price of gold gets fixed twice a day.”

The key requirements for the website included:

  • Provide a graphical view that would indicate the five members buying, holding or selling gold.
  • Build an interactive charting facility so that users can chart historic gold fixes.
  • Integrate site with Rothschild CMS (Content Management System).

Five fixers

Catics Lts also created an updated version of The Rothschild Family website http://www.rothschild.info/ (2003) and also created The Rothschild Archive website http://www.rothschildarchive.org/ (2001, 2003).

Barclays and Sapient

When NM Rothschild departed from the Gold Fixings in 2004 and sold its fixing seat to Barclays, it appears that Rothschild also handed over the responsibility for the website to Barclays, who at some point employed Sapient in a technical capacity for the website. The domain lookup for the site most recently lists a technical support contact for the website of Sapient, with an address of Eden House, 8 Spital Square, London E1 6DU, and an email contact of barclaysmsosupport@sapient.com.

Sapient barclaysmsosupport

Eden House is the London office HQ of Sapient Global Markets. Sapient Global Markets is part of the Publicis.Sapient group, and provides various financial market consultancy and technological services to “capital and commodity market participants” including numerous financial exchanges and clearing houses. Publicis Groupe acquired Sapient in November 2014.

The Sapient phone number +91 1246724778 is an Indian-based number of a Sapient Nitro office in sector 21 of Unitech Infospace in Gurgaon near New Delhi. Sapient Nitro is another division of the Publicis.Sapient Group.

The ‘MSO Support’ in barclaysmsosupport@sapient.com refers to Managed Service Operations (MSO), which is an area within Sapient Nitro’s systems integration practice, which operates from various places including Gurgaon in India. This MSO support team was responsible for the www.goldfixing.com web site that was permanently switched off on the morning of 23rd March 2015.

That Sapient was responsible for the www.goldfixing.com web site is a fact because their indian team in Gurgaon confirmed to me early on the morning of 23rd March that the website had been shut down, as follows:

goldfixing thanks and regards

Furthermore, on their email to me, Sapient (Gurgaon) used the following two Sapient email addresses connected to the Gold Fixing and the goldfixing.com website:

londonpricefixing Sapient

Barclays MSO Support Sapient

A managed service operations team would generally be responsible for content management and delivery, as well as underlying web applications and servers etc.

Before the plug was pulled on the www.goldfixing.com website, fixing prices and associated trading data and gold bar quantities always appeared rapidly on the GoldFixing website straight after the 10.30am and 3.00pm fixings were completed, along with accompanying timestamps down to the exact second.

For example, on 23 October 2014, the morning gold fixing completed at 10:31:16. This information was rapidly updated on to the goldfixing website, as well as being sent out to all the major data vendors such as Bloomberg and Thomson Reuters:

goldfixing snapshot daily price and timestamp

Distribution of near real-time price data could not have been done without an electronic system that captured the fixing data, stored it in a database table, and fed it to a front-end website query.
Likewise, the historical price, bid-offer, bar total and date data which were viewable on the goldfixing website would also have needed to be stored in a database table and accessible via a website query. For example, see the last historical data of gold fixings  from 18th and 19th March 2015 to be displayed on the old goldfixing website before it was switched off:
gold fixing website historial previous days data

This fixing data that appeared on the goldfixing website has to have been supplied by other connected systems such as a fixings order capture and processing system. There cannot be website outputs within inputs, which by definition implies that there are also calculations performed as well as storage and retrieval. i.e. information systems and not ‘pencils’ and ‘bits of paper’ as some of the financial media seem to think the modern daily fixings made use of.

Managed Service Operations (MSO) offerings from companies such as Sapient, often include software/services that facilitate collaboration, and there are also lots of ready-made collaboration applications available on the market. For example, Microsoft Online Services is a server hosted enterprise software suite that can include Office Communications Online, Microsoft Office Live Meeting, and Sharepoint Online. Suffice to say, these products/services (which can be locally or cloud hosted) provide on-line real-time instant messaging and communications (Microsoft Communications Online), live conferencing with video and audio and messaging (Microsoft Live Meeting), or a collaboration platform (Microsoft Sharepoint Online). Citrix also offers a lot of products/solutions in this space such as GoToMeeting.

So some of the above types of software/services would fit the bill for providing precious metals traders’ workstations with web-based commentary, and messaging and communication apps that could be used in the daily fixings alongside phones. Outputs from some of the above could also be integrated into web site price data feeds through messaging middleware.

But there is another more important connection between the London Gold Market Fixing Company and Sapient Global Markets which points to another Sapient app being more than a web-based ‘commentary’.

 

The replacement Gold Fix – Request for Proposals

When the London Gold Market Fixing Limited (LGMFL) and the London Bullion Market Association (LBMA) launched a Request for Proposals (RfP) to administer the new LBMA Gold Price auction on 4th September 2014, Sapient Global Markets was one of the applicants to submit a proposal. This proposal was submitted in conjunction with Autilla Ltd. Previously, for the silver fixing replacement in mid 2014, Autilla initially submitted a standalone proposal, and then in the final week in early July, teamed up with the London Metal Exchange (LME) on a joint bid. Interestingly though, for the gold fixing proposal, Autilla joined up with Sapient in a joint bid on Day 1, so Autilla must have deemed a joint bid with Sapient as being advantageous.

Out of eight proposals received, the Autilla/Sapient proposal was among five proposals to get short-listed by the LBMA, and although they didn’t win the new contract, Autilla/Sapient did make a presentation of their proposal at the LBMA closed-door ‘market’ seminar on 24th October which saw presentations by the five short-listed parties. Note also that there was a third member of this Sapient/Autilla partnership called ‘Global Rate Set Service’, which was also referred to in the proposal as ‘Global Rate Set System’ and ‘GRSS’. This appears to be Global Rate Set Systems, a New Zealand based company.

Sapient letterhead

In the Sapient/Autilla proposal summary,  which takes the form of  a 2-3 page letter to the LBMA dated 27th October, Page 2 describes a ‘current process‘ and also modifications for the new proposed process.

Reading Page 2 of the proposal, its clear that Sapient are intimately familiar with the ‘current process‘ and they only suggest ‘making changes’ to the current process where needed. Sapient state:

“Our solution is one that has a look and feel which is easily recognisable and known to those already familiar with the current process.”

Sapient’s reference to an ‘easily recognisable and known‘ ‘look and feel‘ of its proposed system suggests that ‘those already familiar with the current process‘ were familiar with a similar system.

‘Look and feel’ is a term that’s most commonly used in software development and nowadays rarely means anything outside the software industry. Just google ‘look and feel’ with or without the quotes to see what I mean. In software solutions, ‘look and feel’ will almost always mean “the appearance and function of a program’s user interface”, or “the design and formatting of a graphical user interface (GUI).”

Sapient is saying that those who were using the current process at that time in October 2014 (i.e. the traders of the remaining four fixing members ) would recognise and know an existing graphical user interface that they were familiar with when looking at Sapient’s proposed new graphical user interface.

Sapient states that it has ‘kept’ seven ‘main functions’ of the current process, and then goes on to list the functions that it has kept; these functions include participants logging in, participants entering indicative bar Buy, Sell and No Interest orders in bar amounts, a virtual Flag, matching within tolerance (50 bars), sharing out bars within tolerance, and fx rate pricing:

Sapient app functionality

Sapient then lists the “new or modernised‘ ‘changes’ it is proposing ‘to achieve additional objectives of modernisation, transparency and regulatory cover‘. These new or modernised changes include house and client trades, intra-round price determination, real-time pricing commentary for full distribution, and a GUI messaging portal. Connecting in to the fixing via the messaging portal suggests that any previous messaging would have been done through standalone messaging/chat apps (like those used by interest rate and fx traders).

Interestingly, the Sapient proposal refers to automating some of the tasks that were done by the chairman of the Fixings which sounds like this entailed releasing the final fixing orders for matching, and then processing trade confirms etc.

Sapient new functions

In its proposal to the LBMA, Sapient therefore appears to be describing an existing electronic networked order capture and processing system that the gold fixing process was already using (up until Thursday 19th March 2015). It makes perfect sense then that Sapient had the contract to run the www.goldfixing.com website if it was also responsible for building, maintaining and supporting other parts of the recent gold fixing technical architecture.
Gold Fixing Document Retention Policy

That networked technology was used within the daily gold fixings prior to the transition to ICE’s WebICE is also supported by the  requirements of the “Document Retention Policy” of the London Gold Market Fixing Company, dated 29 October 2014.

This Document Retention Policy, in section 2.3, states that the chairperson of the fixing process is responsible for keeping a record of the following data: member firms participating on each call, names of the individuals from each firm, opening price and sources of opening price, prices tried during the fixing, “bid and offer figures of each member firm at each price tried”, final fix price in dollars, euros and pounds, the time the price was fixed, euro and sterling exchange rates used to determine the fix price, and volume of transactions executed between participating member firms. That is a lot of data to have to record manually twice, each and every day, so again, this suggests that the chairman was not recording this information manually.

Note: As part of the application process to run the new gold fixing, all parties who submitted bids to the LBMA, including Autilla/Sapient, had to sign a non-disclosure agreement (NDA) with the LBMA, so it would be difficult to verify the technical details behind the Sapient/Autilla proposal, as they are most likely covered under the NDA and could not be revealed without the permission of the LBMA.

2004: A Price Oddity  –  Web-based App & Gold Price Manipulation?

There is also an interesting correlation between the timing of a web-based application being launched for the Gold Fixing in 2004 and the timing of alleged gold price manipulation beginning in 2004.

On 28 February 2014, Bloomberg’s Liam Vaughan wrote an article titled “Gold Fix Study Shows Signs of Decade of Bank Manipulation“, which stated that:

The London gold fix, the benchmark used by miners, jewelers and central banks to value the metal, may have been manipulated for a decade by the banks setting it, researchers say.

Abrantes-Metz and Metz screened intraday trading in the spot gold market from 2001 to 2013 for sudden, unexplained moves that may indicate illegal behavior. From 2004, they observed frequent spikes in spot gold prices during the afternoon call. The moves weren’t replicated during the morning call and hadn’t happened before 2004, they found.

Large price moves during the afternoon call were also overwhelmingly in the same direction: down. On days when the authors identified large price moves during the fix, they were downwards at least two-thirds of the time in six different years between 2004 and 2013. In 2010, large moves during the fix were negative 92 percent of the time, the authors found.

There’s no obvious explanation as to why the patterns began in 2004, why they were more prevalent in the afternoon fixing, and why price moves tended to be downwards, Abrantes-Metz said in a telephone interview this week.

 Could the introduction of a trading desk web-based application into the fixings in 2004, which would have provided gold trading desks with extra eyes into the auction proceedings, have presented a means for facilitating a type of gold price manipulation which previously was not possible during the purely phone based meetings held at Rothschilds in St Swithins Lane?

 

fca stairs

The FCA, Barclays and Daniel Plunkett

On 23rd May 2014, the UK’s Financial Conduct Authority (FCA) announced that they were fining Daniel Plunkett, a former Barclays trader and director of its Precious Metals Desk, for manipulation of the gold price during the afternoon gold fix on 28 June 2012, and also fining Barclays for breaches of two Principles of the Authority’s Principles for Businesses between 7 June 2004 and 21 March 2013.

The FCA’s ‘Final Notice’ explaining the fining and prohibition of Daniel Plunkett, provided details of Plunkett’s trading into the gold fix on the afternoon of 28 June 2012. The ease and speed with which Plunkett, on two occasions, rapidly placed and then cancelled proprietary trades into the gold fixing during the fixing that afternoon, suggests that he was using an automated order entry system to place and cancels those trades, and also to unwind the second trade after the fixing completed.

Indeed, at that time in 2012, Barclays’ systems did not differentiate between a Gold Fixing trade executed by a Barclays trader and a gold spot market trade executed by that same trader. And since proprietary gold spot trades would be entered electronically, so too would Gold Fixing trades.

According to section 4.14 of the Final Notice document on Plunkett:

At 3:06 p.m., shortly after the Chairman had increased the proposed price to USD1,558.50, Mr Plunkett, who had not placed any previous orders during the Gold Fixing, placed a large sell order of between 40,000 oz. (100 bars) and 60,000 oz. (150 bars), with Barclays’ representative on the Gold Fixing. This order was incorporated by Barclays’ representative into Barclays’ net position, which led to Barclays declaring itself to be a seller of 52,000 oz. (130 bars).”

At 3:07 p.m. Mr Plunkett withdrew his entire sell order, which resulted in Barclays’ representative withdrawing Barclays’ position (selling 130 bars). This reduced the imbalance in the 28 June 2012 Gold Fixing from 190 bars to 60 bars (155 bars buying/215 bars selling)” Section 4.17

At 3:09 p.m., Mr Plunkett again placed a large sell order, 60,000 oz. (150 bars), with Barclays’ representative, who, also taking into account changes in customers’ orders, declared Barclays’ net position in the 28 June 2012 Gold Fixing to be selling 40,000 oz. (100 bars).” Section 4.21

Shortly after the conclusion of the 28 June 2012 Gold Fixing, Mr Plunkett repurchased 60,000 oz. (150 bars) of gold by executing an internal trade with Barclays’ Gold Spot Book. The purpose of executing this order was to unwind the 60,000 oz. (150 bars) position he had taken during the 28 June 2012 Gold Fixing.” Section 4.24

If an internal trade that Plunkett executed with the gold Spot Book could unwind an outstanding trade that he placed into the Gold Fixing, then the two trades, and the manner in which they were input would need to be similar, which, we will see below that they were.

Barclays –  Gold Fixing trades were identical to Gold Spot trades

The FCA also issued a ‘Final Notice’ detailing the background to the financial penalty imposed on Barclays,  for Barclays’ failure to , amongst other things, create systems on its precious metals desk “that allowed for adequate monitoring of traders’ activity in connection with the Gold Fixing”. The Barclays “Precious Metals Desk” was Barclays trading desk responsible for gold, silver, platinum, palladium and rhodium.

“The systems and reports did not formally record orders placed by traders in the Gold Fixing until 5 February 2013 and did not identify Gold Fixing transactions separately from general gold spot trades until 21 March 2013. As a result, Barclays was unable to adequately monitor what trades its traders were executing in the Gold Fixing or whether those traders may have been placing orders to affect inappropriately the price of gold in the Gold Fixing.” Section 2.3

Barclays relied upon systems and reports that did not differentiate between Gold Fixing and gold spot market trades executed by its traders. (Barclays addressed this on 21 March 2013, when it updated its systems to specifically record Gold Fixing trades as such.) This meant that during the Relevant Period, Barclays could not adequately monitor its traders’ orders and trades executed in the Gold Fixing.” Section 4.36

So, section 2.3 and section 4.36 of this FCA Final Notice tells us that in 2012, gold fix trades executed by Barclays traders were seen as identical to gold spot trades executed by those same traders, and that both sets of trades used the same systems. Plunkett was not being monitored and was independently executing trades that were identical to gold spot trades, and these trades were flowing into Barclay’s net gold fixing position. This would have required an electronic trading platform. If Barclay’s house and customer gold fixing trades were on a technological platform in 2012, then the whole notion of the gold fixing orders with the other fixing participants also not being integrated into an electronic platform prior to 2015 is implausible.

The rapidity with which Plunkett engaged actively in the afternoon gold fixing on 28 June 2012 was also reiterated in the FCA’s Final Notice for Barclays:

“On 28 June 2012, a Barclays trader, Mr Daniel Plunkett, participated actively in the Gold Fixing” Section 2.6

“In particular, he placed a large sell order of between 40,000 oz. (100 bars) and 60,000 oz. (150 bars) with Barclays’ representative on the Gold Fixing, then withdrew it completely one minute later and subsequently placed another large sell order of between 40,000 oz. (100 bars) and 60,000 oz. (150 bars) two minutes after that.” Section 2.9

The move by Barclays on 21 March 2013 to finally differentiate between prop trader executed gold spot trades and prop trader executed gold fixing trades, also suggests that whatever the change was, it took an existing transaction type of gold spot trade and reflagged it as a gold fixing trade. These changes would have all been conducted on a pre-existing electronic platform (since the gold spot book was on an electronic platform), again undermining the notion of a purely pens and paper supported approach to the gold fixing using a system largely unchanged for nearly a century.

Interestingly, neither of the FCA Final Notices issued in connection with Barclays, Plunkett and the gold price, nor any other FCA comments on its investigation into precious metals manipulation in London, make any reference whatsoever to whether the FCA examined  precious metals traders’ messaging app logs or other trader online communication dialogues. This is odd given that messaging apps were seen to have been widely used by all other traders in the recent LIBOR and FX price manipulation scandals. See here for some LIBOR examples and here for some FX examples of trader transcript manipulation chats.

Given that there appears to have been a web-based commentary in the gold fixings since 2004, as well as very sophisticated gold fixing order and price data capture in Barclays systems and in the most recent iteration of the Sapient supported goldfixing website, perhaps the financial media can take a look into this before claiming with certainly that the gold fixings only went on to an electronic platform during the 20th March 2015 transition to the ICE/IBA/LBMA Gold Price architecture.