Tag Archives: price manipulation

Death Spiral for the LBMA Gold and Silver auctions?

In a bizarre series of events that have had limited coverage but which are sure to have far-reaching consequences for benchmark pricing in the precious metals markets, the LBMA Gold Price and LBMA Silver Price auctions both experienced embarrassing trading glitches over consecutive trading days on Monday 10 April and Tuesday 11 April. At the outset, its worth remembering that both of these London-based benchmarks are Regulated Benchmarks, regulated by the UK’s Financial Conduct Authority (FCA).

In both cases, the trading glitches had real impact on the benchmark prices being derived in the respective auctions, with the auction prices deviating noticeably from the respective spot prices during the auctions. It’s also worth remembering that the LBMA Gold Price and LBMA Silver Price reference prices that are ‘discovered’ each day in the daily auctions are used to value everything from gold-backed and silver-backed Exchange Traded Funds (ETFs) to precious metals interest rate swaps, and are also used widely as reference prices by thousands of precious metals market participants, such as wholesalers, refineries, and bullion retailers, to value their own bi-lateral transactions.

Although the gold and silver auctions are separately administered, they both suffer from limited direct participation due to the LBMA only authorising a handful of banks to directly take part. Only 7 banks are allowed to participate directly in the Silver auction while the gold auction is only currently open to 14 entities, all of which are banks. Limited participation can in theory cause a lack of trading liquidity. Added to the mix, a central clearing option was introduced to the LBMA Gold Price auction on Monday 10 April, a day before Tuesday’s gold auction screw-up. The introduction of this central clearing process change saw four of the direct participants suspended from the auction since they had not made the necessary system changes in time to process central clearing. This in itself could have caused a drop in liquidity within Tuesday’s gold auction as it reduced the number of possible participants.

Other theories have been put forward to explain the price divergences, such as the banks being unwilling to hedge or arbitrage auction trades due to the advent of more stringent regulatory changes to prevent price manipulation. While this may sound logical in theory, no one, as far as I know, has presented empirical trade evidence to back up this theory. There is also the possibility of deliberate price manipulation of the auction prices by a participant(s) or their clients, a scenario that needs to be addressed and either ruled out or confirmed.

ICE Benchmark Administration (IBA), the administrator of the LBMA Gold Price, also introduced a price calculation Algorithm into the gold auction in mid-March 2017, a change which should also be considered by those seeking to find a valid explanation for the gold auction price divergence where the opening price kept falling through multiple auctions rounds whilst the spot price remained far higher. Could the algorithm have screwed up on 11 April?

Whatever the explanations for the price divergences, these incidents again raise the question as to whether these particular precious metals auctions are fit for purpose, and why they were designed (and allowed to be designed) at the outset to explicitly block direct participation by nearly every precious metals trading entity on the planet except for a limited number of London-based bullion bank members of the LBMA.

LBMA Silver Price fiasco

First up, on Monday 10 April,  buried at the end of a Reuters News precious metals market daily news wrap was a very brief snippet of news referring to an incident which dogged the LBMA Silver Price during Monday’s daily auction (an auction which starts at midday London time). According to Reuters:

“silver prices slipped after the LBMA silver price benchmark auction was paused for 17 minutes after a circuit breaker was triggered when the auction price moved outside of the spot range, the CME said in a statement.”

What exactly the CME meant is unclear because whatever statement Reuters was referring to has not been released on the CME Group website or elsewhere, and Reuters did not write a separate news article about the incident.

To recap, the LBMA Silver Price is administered by Thomson Reuters on a calculation platform run by the CME Group, and operated on a contract basis on behalf of the London Bullion Market Association (LBMA). However, there is nothing anywhere on the CME’s LBMA Silver Price web page, or on the Thomson Reuters LBMA Silver Price web page, or on the LBMA website, in the form of a statement, comment or otherwise, referring to this ‘circuit breaker’ that persisted for ’17 minutes’ in the LBMA Silver Price auction during which time the ‘auction price moved outside of the spot range

On its calculation platform, CME makes use of a pricing algorithm to automatically calculate a price for each round of the LBMA Silver Price auction (excluding the first auction round). From page 8 of its LBMA Silver Price Methodology Guide:

“3.7 Starting 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….”

“3.4 End of Round Comparison

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.”

There is also a manual price override facility which can be invoked if needed:

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.”

As to why the “auction platform operator” did not invoke these manual override powers and seek market data sources during the time in which the silver auction was ‘stuck’ for 17 minutes is unclear. A 17 minute pause would presumably be, in the CME’s words, ‘exceptional circumstances’.

Unfortunately, neither the CME website, the Thomson Reuters website, or the LBMA website provides intra-round pricing data for the LBMA Silver Price, so anyone who doesn’t have a subscription to the live data of the auction is well and truly left in the dark as to what actually happened on Monday 10 April. Unlike the LBMA Gold Price auction which at least provides an ‘Auction Transparency Report’ for each auction (see below), the LBMA Silver Price auction is sorely lacking in any public transparency whatsoever.

But what is clear from the Reuters information snippet is that the LBMA Silver Price auction on Monday 10 April suffered a serious trading glitch, that saw the prices that were being formed in the auction deviate from where the silver spot price was trading during that time. This price deviation suggests a lack of trading liquidity in the auction and/or an inability of the participants to hedge their trades in other trading venues. As to whether the final LBMA Silver Price that was derived and published as the daily benchmark price on 10 March was outside the spot range (and above or below spot) is not mentioned in the Reuters report.

The complete opacity about this incident is concerning but not really surprising since nearly everything in the London precious metals markets is shrouded in secrecy, and corporate communication in this area is truly abysmal.

Recalling that Thomson Reuters and CME announced in early March that they are abruptly pulling out of the contract for administrating and calculating the LBMA Silver Price, this latest fiasco is unwelcome news for the LBMA – CME – Thomson Reuters triumvirate, and raises further questions for the FCA as to whether this Silver auction and benchmark should even be allowed to continue in its present or similar form.

LBMA-Gold-Price

LBMA Gold Price fiasco

Turning to the London gold auction, on the afternoon of Tuesday 11 April, the LBMA Gold Price auction (which starts at 3:00pm London time) experienced what can only be described as a shocking and serious trading fiasco which has real world consequences for all trading entities that use the LBMA Gold Price Benchmark reference price (and there are many that do so). As a reminder, ICE benchmark Administration (IBA) administers the daily LBMA Gold Price auctions on behalf of the LBMA.

Again it was Reuters that broke the gold auction news. In a short article titled ‘London gold benchmark fixes $12/oz off spot price‘, Reuters said the following:

London’s gold price benchmark fixed some $12 below the spot price on Tuesday afternoon as the auction appeared to become locked in a downward spiral. From an initial $1,265.75, close to the spot price at the time, the auction price ratcheted steadily lower before fixing at $1,252.90 in the ninth round. From the fifth round to the eighth the bid and offer volumes remained frozen, unable to match.

This came a day after ICE introduced clearing for the LBMA Gold Price auction”

Reuters concludes its article by noting that the ICE clearing was introduced:“before several participating banks had the necessary systems in place.”

“As a result, China Construction Bank, Societe Generale, Standard Chartered and UBS  are yet to confirm a date for their participation in the cleared auction.. ICE declined to comment. The LBMA, which owns the intellectual property rights to the auction, was not immediately available to comment.”

This forced reduction in the number of participants in the auction seems to be relevant to the issue and therefore requires further scrutiny.

ICE Central Clearing – Foisted on the LBMA Gold Price auction?

In mid-October 2016 during the LBMA precious metals conference in Singapore, ICE Benchmark Administration announced that it would introduce central clearing into the London Gold Price by utilizing a series of daily futures contracts which it planned to launch in February 2017. The introduction of central clearing into the auction was initially planned for March 2017.

The LBMA Gold Price Oversight Committee meeting minutes for 4 November 2016 specify the March 2017 launch date and make clear that all banks ‘wanted to move‘ to use the clearing route, and that ICE Benchmark Administration ‘wish to keep running a healthy auction‘ (whatever that means). The minutes stated:

“IBA gave a central clearing update to the Committee, notifying them that the cleared instrument would be launched in January 2017 and the auction trades could be routed there from March 2017. The Committee were informed that IBA had spoken to every bank and every bank wanted to move. Discussion moved to the technical implications for this new model and IBA’s primary wish to keep running a healthy auction.”

Up until at least the end of February, ICE’s LBMA Gold Price page stated the following:

From March 2017, subject to regulatory review, centrally cleared settlement will be available for transactions which originate from IBA’s gold auction underlying the LBMA Gold Price.

This will give firms the choice of settling their trades bilaterally against each counterparty (as they currently do), or submitting their trades to clearing and settling versus the clearing house. This mechanism removes the requirement for firms to have bilateral credit lines in place with all of the other Direct Participants in the auction.

Central clearing opens the auction to a broader cross-section of the market. It also facilitates greater volume in the auction.

By the end of March 2017, the above statement had been altered from March 2017 to “Q2 2017″ with ICE pushing back the launch date for the introduction of central clearing:

From Q2 2017, subject to regulatory review, centrally cleared settlement will be available for transactions which originate from IBAs gold auction underlying the LBMA Gold Price….”

Reuters again covered these ICE clearing delays in a series of articles during March, highlighting the fact that 4 of the 13 banks that are direct participants in the LBMA Gold Price auction were not ready for the introduction of central clearing due to delays in making unspecified changes to their internal IT systems that would allow such central clearing processing. So anybody who had been reading these Reuters articles would have been aware that there were risks on the horizon in terms of some of the LBMA Gold Price auction participants being slow in being ready for the changes.

In a 15 March article titled ‘London gold rush - ICE to launch clearing before banks are ready‘, Reuters said that ICE would introduce central clearing to the auction on 3 April and that:

“U.S.-based exchange operator ICE has already pushed back the launch of its service by several weeks to allow the banks and brokers who participate in the auction to adapt their IT systems, four sources with direct knowledge of the matter told Reuters.”

 “Sources at many participant banks said that they were unhappy with the speed at which ICE was seeking to introduce clearing, which require investment in IT processes and back office systems and raise complex compliance issues.

 “However, at least four of the 14 banks and brokers who participate in the LBMA Gold Price auction will still not be ready to use the new system

Banks that are not ready would be suspended from the auction until they have the necessary IT infrastructure in place or would have to participate through other players who could clear deals, according to the sources. 

ICE’s readiness to provoke such disruption illustrates how much it wants to avoid further delays that could torpedo its ambitions to become the dominant exchange in London’s vast bullion market, market sources said”

Reuters picked up this theme again on 21 March with an article titled “ICE delays launch of clearing for London gold benchmark: sources“, in which it said that the 3 April start date had again been pushed back and that:

“two sources told Reuters that ICE had again delayed and there was now no set start date.”

“Sources earlier told Reuters that Societe Generale, Standard Chartered, ICBC Standard Bank and China Construction Bank would not be ready to clear the LBMA auction in time for April 3.”

Again interestingly, ICE’s desire to promote its own gold futures contracts was seen as a primary driver for trying to rush through the introduction of central clearing for the gold auction, as doing so would add volume to ICE’s daily gold futures contracts:

“market sources say ICE plans to use clearing of the LBMA Gold Price auction, which it administers, to funnel business to its contracts and give it a head start over rivals.”

As a reminder, ICE and CME have both recently launched gold futures contracts connected to the London market, and the London Metal Exchange (LME) plans to launch its own suite of London gold futures contracts in early June.

Central clearing uses exchange for physical (EFP) transactions in the daily futures contracts which are then cleared at ICE Clear US. The futures have daily settlement each day between 3:00 pm and 3:05 pm London time. But how the whole process ties together is still quite puzzling. An email to the IBA CEO asking for details of how the futures are linked to the auction went unanswered.

Both the ICE and CME contracts had a damp squib start, experiencing weeks of zero trading volumes. See BullionStar article from 8 February 2017 titled “Lukewarm start for new London Gold Futures Contracts”.

On 30 March, Bloomberg announced on Twitter that central clearing in the LBMA Gold Price auction would start on Monday 10 April.

death

Downward Spiral

So what was this downward spiral that the LBMA Gold Price auction experienced on the afternoon of Tuesday 11 April when it became, in the words of Reuters, locked in a downward spiral?

Let’s look at the ICE Auction Transparency Reports for the few days before and during the 11 April afternoon fiasco. These reports show the number of auction rounds, the number of participants,and the bid and offer volumes for each round as well as the price at the end of each round.

Fourteen entities are now authorized to be direct participants in the LBMA Gold Price auction, 13 of which are banks, the other being new participant INTL FCStone since early April. INTL FCStone is a financial services company that has a slant towards commodities. The 13 banks are:

  • Bank of China
  • Bank of Communications
  • China Construction Bank
  • Industrial and Commercial Bank of China (ICBC)
  • Goldman Sachs
  • HSBC Bank USA
  • JPMorgan Chase Bank (London Branch)
  • Morgan Stanley
  • Société Générale
  • Standard Chartered
  • The Bank of Nova Scotia – ScotiaMocatta
  • Toronto-Dominion Bank
  • UBS

Unlike the old London Gold Fixing which had 5 member banks that were obliged to always turn up (and since 2004 dial in) for every auction, this LBMA Gold Price auction does not require all the authorized participants to dial-in. Most of the time, far fewer than the full contingent turn up. For example on Friday 7 April, 8 banks turned up at the morning auction while only 7 banks turned up at the afternoon auction (i.e only a 50% turnout). However, Friday 7 April is also relevant since that was the last day before ICE introduced central clearing to the gold auction.

7 April AM
LBMA Gold Price auction – 7 April – morning – click to enlarge
7 april PM
LBMA Gold Price auction – 7 April – afternoon – click to enlarge

Fast forwarding to the morning gold auction on Monday 10 April when ICE first introduced central clearing, you can see from the below auction report that only 5 banks participated. This is the same small number that took part in the former London Gold Fixing which was run by the infamous and scandal ridden London Gold Market Fixing Limited and which consisted of Deutsche Bank, Barclays, HSBC, Scotiabank and Société Générale.

The reason the turnouts after the introduction of central clearing are so low is that 4 of the direct participant banks have been excluded from the auction due to not being ready to implement central clearing  – a fact predicted by Reuters News in March. This means that the usual number of between 7-10 banks participating in the auction has now been reduced by 4, as four banks cannot take part. As Reuters said on 21 March “Banks that are not ready would be suspended from the auction until they have the necessary IT infrastructure in place”.

The irony of this debacle is that the participating banks all already have bilateral credit limits with each other and so don’t need to do central clearing in the auction. Only new /future direct participants which do not have bilateral credit lines technically need to utilize the clearing solution.

Central clearing is supposed to make it easier for a far wider range and number of participants to take part. But if this entails enhancements to IT systems that some of the most sophisticated investment banks on the planet are struggling with, what hope is there for other precious metals trading entities to participate.

But some reason – probably to try to kickstart the trading volume in its daily gold futures contracts – ICE has made it mandatory for all existing direct participants (the bullion banks) to open clearing accounts and get their IT systems in shape to use clearing.

The ICE website now states:

“Central clearing  for the auction is enabled by effecting  Exchange for Physical (“EFP”) transactions into the new physically settled, loco London gold daily futures contract which is traded on ICE Futures U.S. The EFPs establish positions in the futures contract which are cleared and can be physically delivered at ICE Clear U.S

and Direct participants (DPs) “must establish a clearing account with an ICE Clear U.S. Clearing member” so as to be able to use this account to clear auction trades.

However, “DPs may still maintain credit lines to settle bilaterally against other DPs” and “DPs can elect, for each counterparty, to clear or settle their auction transactions bilaterally.” If this is so, then why the need to force these banks to open a clearing account and push through complex IT changes?

The ICE LBMA Gold Price web page now includes a double asterisk next to the names of the culprit banks that are not ready for central clearing. These banks are China Construction Bank, Société Générale, Standard Chartered, and UBS. the double asterisk states that “** Date of participating in the cleared auction to be determined.

So now, more than 2 years after the LBMA Gold Price has been introduced, we are back to a situation where only 5 large bullion banks are participating in a daily gold price auction, an auction which has huge ramifications for the reference pricing of gold across myriad gold markets around the world.

Both of the auctions on 10 April finished within the first round, with buy volume and sell volume in balance, so there was no need for subsequent auction rounds.

10 April AM
LBMA Gold Price auction – 10 April – morning – click to enlarge
10 April PM
LBMA Gold Price auction – 10 April – afternoon – click to enlarge

Turning to the morning auction of Tuesday 11 April, only a measly 4 banks took part in the first round of the auction, and 5 participants took part in rounds 2 and 3. The bid and ask volumes were not that much out of balance, and the auction finished after 3 rounds.

11 April AM
LBMA Gold Price auction – 11 April – morning

Turning to the afternoon auction of 11 April, the price action commentary provided by Reuters was as follows:

from an initial $1,265.75, close to the spot price at the time, the auction price ratcheted steadily lower before fixing at $1,252.90 in the ninth round. From the fifth round to the eighth the bid and offer volumes remained frozen, unable to match.

Below you can see visually see what happened round by round from the first round price of $1,265.75 where there was zero bid volume and 125,217 ozs (nearly 4 tonnes) of ask volume, through the fifth to (actually) the ninth rounds where bid volume was an unchanging 92,873 ozs and ask volume was an unchanging 107,090 ozs, but still the price fell from $1,260.50 to fix in round 9 at $1,252.90, i,e, the price fell $7.60 in 2 minutes while the volumes didn’t budge. And most critically, the fixing price was $1252.90 while the spot price was trading at $1267 at that time.

LBMA Gold Price auction - afternoon 11 April 2017
LBMA Gold Price auction – 11 March afternoon – Click to enlarge

As Kitco News said in its coverage of the LBMA Gold Price fiasco:

“the benchmark ended up being set almost $15 dollars below where spot prices were trading at the time. The PM Gold Price showed a benchmark at $1,252.90 an ounce; however at the time, spot gold prices were trading around $1,267 an ounce, with prices heading towards a new five-month high.”

How could this happen? How could the auction price diverge so much from the spot price at that time and how could the auction go through round after round lowering the price while the bid and ask volumes did not change and while the spot price was actually far higher than any of the prices in the auction?

Kitco’s explanation, which is mostly based on the view of one person, Jeff Christian of the CPM Group, put the problem down to “poorly conceived regulations and a faulty price discovery mechanism“, i.e. a lack of liquidity due to banks being scared off by tightening regulations, and that this “sharp reduction in liquidity during the auction process” is causing “a large discrepancy in prices“. Christian also said that “because of regulations, banks and other financial institutions are backing away from becoming market makers.

But this reasoning of backing away due to regulations is not backed up by the facts for the simple reason that banks have continued to join the LBMA Gold Price auction at a rapid rate over the last 2 years, i.e. there is a trend of ever more banks applying to be authorized to participate in the auction. For example, since the auction was launched on 20 March 2015 with 6 banks, 9 more banks have signed up JP Morgan, Morgan Stanley, Standard Chartered, Bank of China, ICBC, China Construction Bank, Bank of Communications, Toronto Dominion Bank, and INTL FCStone. Note that Barclays was one of the original six banks in the auction but dropped out after it downscaled its the precious metals business in London. There are also the same number of LBMA Market Makers now as there were two years ago, in both cases 13 LBMA Market Makers.

Kitco’s article also fails to mention the central clearing implementation fiasco brought about by ICE’s rush to channel activity into its gold futures contracts and Kitco even fails to realize that 4 banks were suspended from the auction due to this central clearing issue.

daily AUD gold futures ICE 11 April
ICE Daily Gold Futures report for 11 April – See Volume and Open Interest – Click to Enlarge

Another factor relevant to the screwed up afternoon auction on 11 April that should be considered is the fact that in mid-March 2017, ICE Benchmark Administration introduced a price algorithm into the LBMA Gold Price auction. This fact has been totally ignored by the financial media.

From a human Chairperson to an automated Algorithm

Up until mid March 2017, the LBMA Gold Price auction used a human ‘independent chairperson’ to choose the opening price in the auction and also the auction price in each subsequent round. The identities of these independent chairpersons have never been divulged by ICE nor the LBMA.

Critically, sometime during the 3rd week of March 2017, ICE Benchmark Administration (IBA) introduced a pricing algorithm into the LBMA Gold Price auction. This change in procedure (moving from an auction chairperson to an auction pricing algorithm) was not actively highlighted by either ICE or the LBMA but is clear from looking at Internet Archive imprints of the ICE LBMA Gold Price webpage.

In an imprint of the LBMA Gold Price webpage from 9 March 2017, the methodology section states that:

“The auction process has an independent chairperson, appointed by IBA to determine the price for each round and ensure that the price responds appropriately to market conditions.”

See screenshot below for the same statement –  taken from the same webpage:

methodology 9 march 2017
LBMA Gold Price webpage – Methodology section 9 March 2017

Bullet point 1 of the Auction Process for the 9 March version of the webpage also refers to the chairperson as being responsible for setting the starting price and the price of each subsequent round “in line with current market conditions and the activity in the auction.

process 9 march 2017
LBMA Gold Price webpage – 9 March

But by 16 March, when the next imprint of the LBMA Gold Price page was made by the Internet Archive, the reference in the methodology section to an independent chairperson had been fully deleted, and bullet point 1 had been changed from mentioning a chairperson to discussing an algorithm, specifically changed to “IBA sets the starting price and the price for each round using an algorithm that takes into account current market conditions and the activity in the auction.

See screenshot below for the same statement –  taken from the same webpage:

process 16 march 2017
LBMA Gold Price webpage – 16 March

So if there is an algorithm that is taking into account current market conditions in addition to activity in the auction, why did this algorithm not take the current spot prices into account over rounds 4 – 9 of the LBMA Gold Price auction on the afternoon of Tuesday 11 April?

Furthermore, for such a major change to the methodology and auction process in an auction whose benchmark price is widely used in the gold world, it’s very surprising that neither ICE, nor the LBMA, nor the London financial media mentioned this substantial algorithmic change.

In early December 2016, ICE published an LBMA GOLD PRICE Methodology Consultation in which one of the consultation’s proposed changes was “the introduction of an algorithm to determine the price for each auction round“.

The December 2016 document noted that:

“IBA’s auction process is currently that the auction chair sets the price for each Round in line with current market conditions and the activity in the auction”

“IBA currently has a panel of auction chairs who are independent of any firm associated with the auction, including Direct Participants. The chairs are externally sourced but work with IBA to deliver a robust process for determination of the LBMA Gold Price.

The chairs use their extensive market experience to set the round prices based on a pricing framework agreed with IBA. IBA chose to operate the auction using human chairs to make sure that the price could respond appropriately to market conditions from the outset.

IBA’s feedback from the market was that, at least in the early stages, the professional judgement of a human chairman was needed.

“After operating the auction for more than a year, IBA started to develop an algorithm to set the auction’s starting price and subsequent round prices. IBA has now been testing and refining the algorithm over a number of months

As per the proposal, the algorithm would replace the human chair, after which:

Each auction will continue to be supervised by IBA’s analysts, and, if for any reason an auction did not progress as expected, IBA’s existing safeguards would be deployed to protect the integrity of the auction and the LBMA Gold Price benchmark

These safeguards were stated as being three, namely:

- Pause the auction and restart, to give Participants an opportunity to contact clients or re-evaluate their positions

- Increase the imbalance threshold, if it appears that the auction will otherwise not finish

- Cancel an order, if it is compromising the integrity of the process and the relevant participant cannot be reached. 

The proposals were pencilled in for implementation in Quarter 1, 2017.

Following the consultation, a “Methodology Consultation Feedback” document was published on the ICE Benchmark Administration website. One feedback respondent was concerned about who would be overseeing the daily auctions in the absence of a human chairperson, to which ICE answered:

“IBA can confirm that the auction will always be supervised by at least two IBA analysts. This approach is consistent with how we operate our other benchmarks.

Our aim is to put the auction on auto-pilot, not to make it driverless.

Unfortunately, from the wider gold market’s perspective, the LBMA Gold Price auction on the afternoon of Tuesday 11 April does indeed appear to have been ‘driverless‘ as it “did not progress as expected“, so it is now up to the LBMA and ICE to establish what the ‘IBA analysts’ were up to behind the driving wheel that day.

On its website, ICE states that the LBMA Gold Price methodology is “reviewed by the LBMA Gold Price Oversight Committee as documented in its Terms of Reference.” This Oversight Committee should also explain to the gold world what actually happened on the afternoon of 11 April.

Additionally, I find no explanation on ICE’s LBMA Gold Price webpage as to how exactly the automated algorithm works, what its logic rules are, how it was programmed etc.

Conclusion

The trading glitch with the LBMA Silver Price on Monday 10 April seems to have been completely missed by London’s financial media except for the brief reference by Reuters. The fact that there is no information on the CME, Thomson Reuters and LBMA websites about the issue should raise concern for users of this benchmark and for the UK’s regulator, the FCA. In an ideal world, there should be a full ‘outage’ report published on each of the 3 websites explaining what happened, but this will not happen in the shadowy and secretive London Silver Market.

Perhaps the auction price divergence in the LBMA Silver Price stems from a lack of liquidity brought on by the limited presence of auction participants, or due to the inability or unwillingness of participants to hedge or arbitrage their auction trades against the London OTC spot or other trading venues? The simple thing to do would be for CME, Thomson Reuters and the LBMA to explain themselves since this would minimize guesswork and to provide global silver market entities with clarity. Anything short of a full explanation by the parties concerned is irresponsible.

For the LBMA Gold Price auction, ICE Benchmark Administration needs to release a full ‘outage’ report and explanation on what exactly happened in the afternoon auction on 11 April and explain to the global gold market whether the introduction of central clearing was in any way responsible for the price divergence, and whether there are any conflicts of interest in trying to get banks to use its daily gold futures contracts. While they are at it, ICE should fully explain how the recent introduction of a pricing algorithm impacts the gold auction and whether this too had an impact on the auction price entering a downward spiral.

As the LBMA Silver Price and LBMA Gold Price are both Regulated Benchmarks, the FCA regulator needs to step up to the plate and for once show that it is on the side of the users of these benchmarks and not the powerful London banks.

Both of these auctions require full transparency and ease of direct participation by the full spectrum of the world’s gold and silver trading entities. Currently, they fall far short of these goals.

Guest Post: How to Trigger a Silver Avalanche by a Pebble: “Smash(ed) it Good”

UBS and other precious metals traders on how to wreak havoc in silver markets

Written by Allan Flynn, specialist researcher in aspects of gold and silver.

avalanche

“An avalanche can be triggered by a pebble if you get the timing right” 

Earlier this year at April’s hearings for London Silver and Gold Fix lawsuits, the judge and defendant’s attorney quipped about trader chats named “the mafia” and “the bandits” published in prosecutors findings of Forex investigations but conspicuously absent from precious metals investigation findings, and the silver and gold antitrust lawsuits under consideration.

THE COURT: “Those were bad facts for the defendants.”

LACOVARA: “I think, your Honor, that if we had chat rooms that said “The Cartel”, we might be having a different focus to oral argument today.”

THE COURT: “I think that is correct.”

Given the judges skepticism of the allegations described in an earlier article, it came as a surprise early October when the banks listed were ordered by magistrate Valerie E. Caproni to face charges. More surprising perhaps was the exemption granted Swiss bank UBS, which despite having been found guilty and fined for “precious metals misconduct” by the Swiss Financial Market Supervisory Authority FINMA in November 2014, was granted motion to dismiss from both silver and gold lawsuits.

All that may be about to change according to documents filed in a New York district court December 7th, where plaintiffs claim that transcripts showing conspiracy to manipulate silver, provided by Deutsche Bank as part of an April settlement agreement, includes extensive smoking gun evidence involving UBS and other banks. Plaintiffs describe a “multi-year, well-coordinated and wide-ranging conspiracy to rig the prices of silver and silver financial instruments that far surpasses” that of the previous complaint, including potentially incriminating evidence of UBS precious metals traders allegedly conspiring with other banks.

Five additional banks to the remaining defendants HSBC and Bank of Nova Scotia are mentioned including Barclays Bank, BNP Paribas, Standard Chartered Bank, Bank of America and Merrill Lynch. The Memorandum of Law signed by Vincent Briganti on behalf of Lowey Dannenberg Cohen & Hart for plaintiffs on Wednesday 7th December seeks leave to amend the existing complaint filed with the United States District Court Southern District of New York.

Included in the memo are numerous astounding transcripts indicating coordination between UBS and other banks of “pushing,” ”smashing,” ”bending,” ”hammering,” ”blading,” ”muscling,” and “ramping” the prices of silver and silver financial instruments.

In support of claims of conspiracy to manipulate the price of silver downward the following gem is attributed to UBS Trader A: “so we both went short” “f*cking hell it just kept going higher” “63,65, then my guy falls asleep, it goes to 69 paid!” “then finally another reinforcement came in.

Discussions supposedly of coordination between UBS and their competitors about fixing the price of physical silver by offering only wide spreads between the bid and ask (where a “lac” is reference to an Indian measure equaling 100,000 units) go like this:

UBS Trader B: “what did u quote let me check”

Deutsche Bank Silver Fix Trader-Submitter A: “44/49”

UBS Trader A: “just quote wider if they call me in 1 lac I will quote 7-8 cents”

Deutsche Bank Trader B: “how wide u making 1 lac today 5 cents?”

UBS Trader A: “silver actually steadier than gold i would make 5-6 cents wide in silver”

UBS Trader A: how wide would you quote 5 lacs silver?”

Deutsche Bank Trader B: “10cu>?”

Deutsche Bank Trader B:”how wide u quote for 3 lacs?”

UBS Trader A: 10 cents”).

Manipulation of the Silver Fix price to benefit their silver trading positions in derivatives by UBS is claimed in the following exchanges:

Deutsche Bank Trader B: “u guys short some funky options” “well you told me to no one u just said you sold on fix”

UBS Trader A: “we smashed it good.”

Deutsche Bank Silver Fix Trader-Submitter A: “UBS boring the market again”…”just like them to bid it up before the fix then go in as a seller…they sell to try and push it back.”

It’s further alleged by plaintiffs that UBS implemented an “11 oclock rule” where both UBS and Deutsche Bank would short silver at 11A.M.

As examples of the comparative ease by which UBS moved the silver market the memo reveals Deutsche Bank Trader B added UBS Trader A to a chat with HSBC Trader B, which UBS Trader A deemed “the mother of all chats,” and leading to the trader’s own analysis:

UBS Trader A to Deutsche Bank Trader B: “if we are correct and do it together, we screw other people harder”

UBS Trader A: “an avalanche can be triggered by a pebble if you get the timing right” and “silver still here, u can easily manipulate silver”, and in reference to UBS supposed manipulative influence by an unnamed party: “u guys WERE THE SILVER MKT.”

hobo

UBS intended to reap financial rewards by manipulation of the price of physical silver and associated financial instruments, the memo says as UBS Trader A suggested: “go make your millions now jedi master…”pls write me a check when u aer a billionare,” and “i teach u a fun trick with silver” to which Deutsche Bank Trader B replied: “show me the money.

Confident of their ability to manipulate UBS made bold predictions according to the following alleged extracts:

UBS Trader A: “gonna bend this silver lower”; “i will bend it lower told u”; ”hah cool its gonna get ugly”; “use the blade on silver rg tnow it’ll hold it up,

Deutsche Bank Trader B: “yeah,

UBS Trader A: “gona blade silver now.

Of course all the secrecy in the world about the operations was required of the chat groups by UBS Trader A stating: “pls keep all these trick to yourself,” “btw keep it to yourself…,” and “ok rule of thumb EVERYTHING here stays here.

Examples of other banks alleged transcripts are included in the following:

Barclays

Deutsche Bank Trader B instructing Barclays trader A: “today u smash,

Barclays Trader A: “yeah” and “10k silver” “im short.

It’s alleged that Barclays and Deutsche Bank shared information so often that Barclays Trader A remarked “we are one team one dream.”

Materials in the memo even include the Deutsche Bank and Barclays precious metals traders agreeing at one stage to “stay away” from silver for a week.

The traders of course knew it was terribly wrong with Barclays Trader A responding to Deutsche Bank’s Trader B instruction to “push silver”: “HAHAHA lol i don’t think this is politically correct leh on chat.

Merrill Lynch

Allegedly fixing the bid-ask spread they offered clients on silver:

Merrill Lynch Trader A: “How wide r u on spot? Id assume 10 cents for a few lacs?

Deutsche Bank Silver Fix Trade-Submitter A: “im getting ntg but stops”

…Merrill Lynch Trader A: “we had similar” “I sweep them…Fuk these guys.

Showing disregard to global regulators even after noting their activities the two continued to “sweep” the silver market, allegedly observing at one stage: “Someone got stopped messily.

smash

BNP Paribas Fortis

Fortis Bank Trader B allegedly conspired with Deutsche Bank to manipulate silver prices, using what he termed a “bulldozer” on the silver market.

Standard Chartered

Conversations between Deutsche Bank Silver Fix Trade-Submitter A and Standard Chartered Trader A as follows:

 “Yeh” “small long out of the fix…” “ok where to sell sivler then?

23.40 thru that use it as a stop profit and let it runnnnnnnnnnnnn

were on the same wavelength

im long silver”…”ilke both [silver and gold] to get the absolute sht squeezed out of them” “im longer silver than i am gold

Conclusion

Assuming the transcripts submitted are accepted and plaintiffs are permitted to file their Third Amended Complaint, the possible pending “avalanche” of settlements in silver lawsuits will speak volumes for the investigative prowess of the CFTC and the DOJ, both of which were commissioned to investigate long running allegations of silver and precious metals market manipulation over recent years, and came up completely empty.

It appears Judge Caproni, former FBI General Counsel, was on the money when considering the potential of ineptitude in government investigations of precious metals markets at April’s gold hearing: “I don’t put a lot of stock in the fact that there are investigations because I was a government lawyer for a long time and I know what you need to open an investigation. By the same token, the fact that they closed it without charging anybody doesn’t mean that everybody is innocent. So I don’t put a lot of stock in it one way or the other.”

The CFTC proudly announced in September 2013 they had spent five years and seven thousand enforcement hours investigating complaints of manipulation in the silver market, including with assistance by the Commission’s Division of Market Oversight, the Commission’s Office of Chief Economist, and outside experts, but yet found nothing.

The Department of Justice Antitrust Division which were so confident of their investigation of collusion in precious metals they went to the extraordinary lengths in January of this year of providing a letter to silver and gold lawsuit defendants advising they had closed their investigation without findings of wrongdoing.

The Swiss Financial Services watchdog FINMA investigated, published and prosecuted UBS for forex and precious metals trading misconduct but yet said so little about precious metals findings in their November 2014 investigation report, it was impossible for the court to withstand UBS motion to dismiss in both metals.

And finally of the ability of authorities to reign in rogue banks in the precious metals or any other markets, the memorandum flags a fact that should draw the attention of those trying to figure out if they can indeed trust that their bullion bank has their best interests at heart simply by banning participation in trader chat rooms.

“The chats contained in the DB material are just the tip of the iceberg, as evidence suggests that Defendants intentionally communicated in undocumented ways to keep their manipulation hidden.”

For example the memo includes the salient reminder that banks will always find a way “to evade detection,” in this case where two traders are described as also communicating “via email and personal cell phone.”

The above article was first published at Allan Flynn’s website here.

Allan Flynn is a specialist researcher in aspects of gold and silver. He is currently investigating for future publication on the same topic and works in property and commercial architecture when he needs to eat. He holds shares in precious metals producers and banks.

 

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.