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SEC Insider Trading Investigation Reveals SEC Is Really Good At Insider Trading Investigations, Anyway
Matt Levine
Sheelah Kolhatkar's cover story today in Bloomberg BusinessWeek about the SEC's hunt to capture Steve Cohen is pretty amazing, and depending on your priors will leave you impressed or infuriated or both with the SEC. I vote both, but I always vote both.
The core of it is the story of how Sanjay Wadhwa, a senior enforcement lawyer at the SEC, got a tip from FBI agent B.J. Kang "that something big might have gone down during the summer of 2008 at SAC Capital," though "It's not clear whether Kang was motivated by information or intuition." This nebulous tip led Wadhwa to research all previous SEC referrals about SAC. One that he found was a "multipage [September 2008] letter from NYSE Regulation ... [that] said that someone from RBC Capital Markets had pointed out evidence of a market-moving information leak about Elan. 'If there was a leak of information,' the letter read, 'it was probably during the ICAD [International Conference on Alzheimer's Disease] conference,' when doctors and investors would have been mingling and socializing." Good tip!
This thesis turned out to be incorrect, but the letter did prompt the SEC to launch one of its largest investigations. It would end up issuing 140 subpoenas and amassing 2 million pages of documents as it built a case that kept leading in the direction of SAC Capital. ... They tried to piece together an explanation for the astonishing amount of money SAC had made trading Elan. ... The initial stages involved painstaking work: The firm's trading records were a jumble of activity with nothing broken out. It was also difficult to discern which of SAC's 900 employees they should focus on. ...
After sifting for months through every phone call to SAC from anyone connected to Elan, the SEC team pinpointed Martoma and his source, a neurologist and Alzheimer's expert named Dr. Sidney Gilman, who worked as a consultant to hedge funds through Gerson Lehrman. ... As they tracked Martoma further back in time, a pattern emerged: Over the course of 2007 and 2008, Martoma and Gilman had spoken every time an Elan safety monitoring committee held a meeting.
Eventually they brought the case to prosecutors who arrested Martoma. Given the public information - mostly from the SEC and prosecutors at this point, but still - it's pretty easy to believe that the SEC and prosecutors have Martoma dead to rights; Gilman has told prosecutors that he gave Martoma tons of inside information and Martoma then traded on it. So this really is - apparently - the story of a dogged team of investigators pursuing a thin lead and, through long hours of rigorous detective work, actually catching a criminal. Not Steve Cohen, but someone one level removed from him.
That is impressive. It's hard dogged work; I am depressing myself just thinking about reading phone records for months on end. They get points for, like, the pure arete of it.
But it also sucks, doesn't it? For one thing, I get an unpleasant whiff of data mining from the story. Lots of insider trading cases are built on circumstantial evidence: Insider X at Company Y called Trader Z on the phone, and two minutes later Trader Z bought a lot of Company Y stock, and then the next day Company Y announced it was being acquired. Insider X and Trader Z were social friends, and without a wiretap you don't know what they discussed, but what are the odds that that would happen innocently?
That's a good question but the answer depends on the sample set. If the odds are one in a million, and the SEC looked into twenty million phone calls between Insider X and Trader Z and other insider-and-trader friend pairs like them and brought only one set of charges, then ... that looks a little different, doesn't it?
This is sort of a churlish thing to point out in this case because by all non-circumstantial indications (Gilman's cooperation, etc.) they got it right here, but still. The sheer amount of records reviewed might make you wonder a little about, say, Rajat Gupta, whose insider-trading tipping conviction was based mostly on an awkwardly timed phone-call-and-stock-buying situation. That call looks ridiculous in isolation, but knowing how many millions of other calls the SEC looked at might change your mind.1
This line of thinking might get you worried about Kolhatkar's discussion of "edge":
When a former trader from Galleon Group was asked what the word "edge" meant to him, he laughed and said that from the day he started at Galleon to the day he left, it was probably the most commonly used term around the office. It was such a priority, the trader added, that if you didn't have it, you'd be quickly left behind. It meant that you knew something that others didn't. Another trader—a witness in the government's insider-trading investigation—was asked if he knew of any hedge fund that didn't traffic in illegal information, according to the person familiar with the inquiry: No, the source answered, they would never survive. In this way, trading on nonpublic material information is similar to doping in professional cycling: Once someone like Lance Armstrong starts doing it, everyone else has to as well. Proving that it's happening is just as difficult. "These cases take real detective work," says Tom Sporkin, a partner at Buckley Sandler and a former senior enforcement official at the SEC. "It's like finding the needle in the haystack."
This is a deeply troubling passage, isn't it? If all "edge" - everything that makes trading informed and markets efficient - is really insider trading,2 then ... well, then, for one thing, prosecuting insider trading might be really bad for market efficiency. But more important spending months pursuing one insider trading case would be crazy! If this witness's theory is right, then sending Raj Rajaratnam or Mathew Martoma or Steve Cohen or anyone else to jail for insider trading is like a random lightning strike: of the thousands of hedge fund traders who, in this weird view of the universe, are all insider trading, why bother putting a couple of dozen in jail?3 Or, if the theory is wrong, but the SEC treats any edge as evidence of wrongdoing and a reason to start an investigation, then ... then they'll be doing a lot of data-mining on anyone who makes money trading?
The main reason to be worried about this investigation, though, is what it says about priorities. I mean, you don't have to be worried about priorities here: if you believe that insider trading is The Most Important Crime, then catching it is The Most Important Thing We Can Do. I don't believe that, and I feel like a lot of people are starting to doubt it, especially after events of the last few years. Lots of financial misbehaviors were revealed, some of which (Madoff, mortgages, CDOs, whatever) had enormous consequences on the financial system and individuals' life savings, and others of which were insider trading.
If you don't believe that insider trading is the most important financial regulatory problem, then you might worry about the sheer person-hours devoted to this case; the millions of documents and thousands of phone calls that consumed all of several skilled SEC lawyers' time for basically three years. Surely that time and money could be spent elsewhere.
But more than that, I feel like this investigation says something troubling about the skills the SEC develops and prioritizes. Finding needles in haystacks isn't a great skill for a financial regulator. It's okay! I mean, insider trading is a little bad, so someone should try to catch it. And other sorts of actually harmful financial crimes share similar characteristics. Would that someone at some regulator had gone looking for an actual bank statement for Peregrine Financial, for instance.
Others, though, less so. Imagine the sort of financial regulator who, blessed with complete granular information about the London Whale's trading positions - which US financial regulators had4 - would call up Jamie Dimon and say "hey you gotta cut back risk in your whalery, not in a bullshit RWA-and-VaR-model-manipulation way but by actually paring down positions." Or the sort of regulator who, after reading her tenth CDO-squared prospectus, would get a little nervous about home-price-appreciation and correlation assumptions and dig into the modeling and call banks to say "hey what is up with this?"
Two questions you might ask are:
Would you want that sort of regulator? and
Is that skill developed by finding the one phone call in a thousand that proves insider trading?
Your answers may vary but mine are "yes" and "no." The paradigmatic SEC investigation - "find an insider trader through phone records" - is about drilling down, not broadening out. It starts from a suggestive general pattern - "boy SAC makes a lot of money" - and looks for the one specific fact to nail somebody. The financial regulators you'd really want would start from specific facts and look for the general pattern. They'd spend years looking for broad problems with systems, not phone records to prove a single instance of wrongdoing by a single person. These SEC lawyers - the ones held up as models of SEC enforcement, the ones responsible for the SEC's one post-crisis success story - should have been finding Bin Laden, not overseeing a financial system.
On the Trail of SAC Capital's Steven Cohen [BBW]
1.And you can even imagine something similar happening here. Not to Martoma, necessarily, but to Cohen, who ended up going from a large long to a large short in Elan stock after a meeting with Martoma, who was in possession of nonpublic information about bad drug trial results. "What are the odds," you'd ask, "that Cohen and Martoma had a totally innocent meeting and then Cohen dumped all his ELN stock and put on a massive short the next day?" Well, low. One in N, for some large N, right? But if I told you that the SEC looked into 5N conversations that Cohen had just before making other big trades, where does that leave you?
Yeah yeah this is different - his secret conversation was with a guy who had inside information - but nobody knows what was said. If Martoma said "my inside source told me to dump ELN," Stevie's cooked. If he gave a deeply researched fundamental argument that made no evident use of inside information, Stevie's just an innocent victim. Again, "what are the odds?" is the right question, but the answer depends on the sample size.
2.By the way you don't have to believe that - I obviously don't - to notice another thing I harp on, which is that all of the evidence is that some sort of insider-trading-lite is pervasive, so why put such emphasis on imprisoning people who do the slightly more obvious version?
Note here that the SEC "sift[ed] for months through every phone call to SAC from anyone connected to Elan." There were apparently months' worth of calls between Elan insiders and SAC. A few of those calls constituted insider trading, in the SEC's telling. The rest did not. Were they purely social?
3.A more subtle theory would distinguish "edge" - just, like, having an idea or information or insight or model or whatever that you believe to be better than what others have - from "black edge," which is apparently SAC's hilarious term for illegal inside information:
[An SAC trader] wrote that Martoma was acting like he had "black edge." A trader's edge is his advantage; it's the work he's done and the things he knows about a company. "Black edge," according to people familiar with the inquiry, is likely a term for information that cannot be doubted and that no one else has. It's the kind that can make a trader millions and the kind that can put a trader in jail.
And the kind that can get a trader laughed at on Twitter.
4.I'm stretching a little because the Whale is topical; he's really more of the Fed's/OCC's purview than the SEC's. Part of that is because the investment banks who were in the SEC's purview all disappeared due, in part, to inept SEC oversight.
Steve CohenSidney GilmanMathew Martomainsider-tradingSAC CapitalSEC
Steve Cohen Had Instant Messenger Debates About Whether His Analysts Were Insider Trading
SAC Puts Ten Days Of Insider Trading Behind It
Doctor Who Tipped Off SAC Manager Wasn't Conspicuous About His Wealth Except When He Was Telling Strangers On Planes About All The Fancy Hotels And Limo Rides Insider Trading Afforded Him
As you may have heard, in addition to the salary he was paid by the University of Michigan, Dr. Sidney Gilman made about $100,000/year through his side-gig advising "a wide network of Wall Street traders." That network included included Mathew Martoma, recently charged with running "the most lucrative insider trading scheme ever," based on the information he received from Gilman, who made it a habit of leaking highly confidential information to the former SAC Capital employee. While most people that engage in fraud can't help but spend their ill-gotten gains in a flashy way that attracts unwanted attention (expensive cars, private jets, chinchilla fur coats) the Times reports that Sid Gilman's supplementary income "was not readily apparent in his lifestyle in Michigan." For instance, no second home and no bragging to his colleagues about his life on Wall Street. Still, on at least one occasion, the doctor couldn't help but let the underage girl sitting next to him on a flight home know that she was in the presence of a BSD.
Steve Cohen Got Nonpublic Information All Day Long, Didn't Think It Was A Big Deal
SAC Can't Even Put Ten Days Of Insider Trading Behind It
Steve Cohen Was Serious About Stopping Insider Trading Unless It Occurred In The 89% Of Emails He Didn't Read
SAC's Rigorous Compliance Program Focused On Coming Up With Euphemisms For Insider Trading
F.B.I. Agents Took Inspiration From I Know What You Did Last Summer In SAC Capital Insider Trading Case


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Madonna :: The "Finally Enough Love: 50 Number Ones" Era
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50M release week?
Like I said, we love an optimist
MadNuno
Originally posted by Artoo View Post
That's among ALL STREAMING SERVICES, not only from Spotify. Only 10M to 16M from Spotify on first week.
Maybe you think it's too much but I believe that with some promo will get there.
I guess many of the remixes (even previously released) got their biggest stream day ever so far yesterday on Spotify!
Promo?
Jesus take the wheel
Global promo (windows at music shops), international news and reports about Madonna and the album and maybe some advertising (on Spotify and maybe even on the radio or TV in some countries).
Until now the only press is from US (as well as her pride performance that only generated news in US so far) and usually there is a media circus surrounding a Madonna new album (even a new compilation). There will be some promo, even if not much, some is better than zero. Besides is Madonna birthday week and so many media talk about her birthday every year (even without being her 40 year career anniversary or having a new album out).
MadNuno baby,nothing of what you described above works ,as far as streaming goes.
So, 16 million on week one for a Madonna remix album is absolutely impossible
I mean Madame X probably hasn't even done a billion streams across all platforms, so I just don't see a remix album doing a 20th of that in week one.
Angeman
Also Hollywood remix is on the Release Radar playlist. It doing on par/less then the first half of the album is um yeah not great.
Originally posted by Angeman View Post
That's a personalised playlist, although yes, mine is also Hollywood. It's a bit of a shame everyone who was playing Frozen Remix hasn't given it a go though.
A bit off topic, but since Madnuno keeps repeating that Spotify is just 30% of the market and simply multiplies its daily/weekly numbers till 100% to get a total market share numbers picture… that's definitely not how it works.
Yes, according to some studies published at the beginning of this year, Spotify has the lead, by a big margin, of the streaming cake with 31% of the total, followed by Apple Music (15%), Amazon Music (13%), Tencent Music (13%) and YouTube (8%).
Does this mean that if she receives 1M on Spotify one week she'll receive the exact proportional streams on each of those platforms according to these market share %? Definitely no.
Tencent Music is the company behind QQMusic and other Chinese stream platforms. Where the vast majority of consumption is from local artists.
Same with other platforms. If one Chinese artist is doing huge numbers on QQ Music I cannot extrapolate those numbers to other streaming platforms…
So, obviously, when calculating numbers from "other platforms" besides Spotify that don't provide figures, you have to take into account the genre, the artist, and definitely the nationality of the artist.
For most western pop acts, Spotify can actually be 50 to 60% or their total streaming numbers.
While Spotify is behind Apple Music in US, for example, is miles ahead in other territories like most of Europe or Latin America.
Not even going to discuss the numbers he's expecting for Spotify on the physical release week as they're obviously not going to happen… But I just wanted to bring some light on the even more crazy numbers expected from other platforms just based on that report of Spotify being 31% of the total market.
Originally posted by BodyShop View Post
I started writing back and just thought whats the point
It is a personalized playlist but the song is the same for everyone who has Madonna in that playlist meaning everyone has Hollywood. Still it should have done a little better imo at least 30k.
Yall are agruing with someone whos literal name is "Mad". From past posts this shouldnt be surprising
Sun June 26, 2022, 00:11
Originally posted by InFamous View Post
Believe me ,that happens to me quite often
Agreed. When the 50 track edition is released maybe they need to push Material Girl to get the Frozen Remix crowd listening.
NoirPhoenix
Not the whole album doing less than the Frozen remix in a day, truly the pits but anyway 9/16 of the remixes were already available and it's not like they're new songs, also awful if they're pushing the Hollywood remix because it's one of the only bad ones from the album, they should have pushed Music.
I guess that by Aug 19th it will have around 5M streams + 19M that it already had = 24M and then with all the new remixes it could have a small chance to debut in the Top 10 on Billboard and in the UK.
UnapologeticKenny
I was hoping for this album to do similar numbers to the Madame X live album, which it did. I'm happy. Like many people said, this is literately a selection of old remixes put together, and unless the remix goes viral or something like that, it never does outstanding numbers because the audience is very limited to the hardcore fans who also happens to enjoy remixes. There are no reason for a random person to play it... no new artist or new song. To be fair I think a live album has even more appeal to the GP than a remix compilation, so for that we should be very thankful.
Originally posted by UnapologeticKenny View Post
The only difference this time is that it's Madonna first major release after the Frozen Remix success - so Hollywood should be in the Release Radar playlist for those who played that a few times… but clearly they didn't even bother checking out the song (unless they did and turned it straight off )
Originally posted by NoirPhoenix View Post
The only way it's going Top 10 anywhere is through physical sales. Streaming will add next to nothing.
Yeah we know that but like I mentioned if it has 19M streams already and then adds maybe 3-4M more by the time it gets released that adds 23M at least and while it's nothing in SEA numbers, even if it adds 2-4K to the total it helps for the album to get a cute position, vinyls and CDs will move around 95% or the total because TEA is dead now.
britneyliam
It won't chart on any country next week I bet
We'll see soon enough
jjavier1978
Madonna is The most successful and influential female artist of all time.
Originally posted by nympho View Post
Partial true, we don't know for sure (it's an average estimative as that's all we can do). I simpliflied the excels I did to get to that data for you.
Numbers are much more complex and even change a lot country to country. I'm not going to do a complex tendency statistic/probabilistic analisys on posts here. Not only would be boring and too complex for most of us to read it right. I can add this info to yours though:
Spotify was 31% during Q2 2021 (down from 33% from 2021 Q1) and YouTube Music (does not includes YouTube Videos except when are premium views) was 8% in Q2 2021 (up from 4% in Q1 2021). You have analyse tendencies as well as the numbers as 1 year have passed since that data.
We do have Madonna numbers for Spotify and YouTube (not as easy to get but they get published - both YouTube Music and YouTube Video). We don't have info about what Madonna streams were free ad supported or premium (except for YouTube video as we all know it's mostly ad suported and not premium).
When Madonna anounced she had 1 million streams on Apple Music she had how much? About 4 million streams on Spotify? Probably she had the same premium streams from Apple Music and Spofity as most Spotify streams are ad supported and not premium.
YouTube MUSIC have 8% but YouTube Video is not included here else YouTube would have the same numbers as Spotify and despite not being part of many countries streams it's streams are counted in many countries (like US and UK) as ad supported streams. Remember that Spotify Streams are around 80% ad supported as well and 20% premium streams while Apple Music are ALL Premium streams (and Spotify Ad Supported streams are also erased from charts and certifications of many countries like France or Germany as well).
Ad supported in US mean 3750 streams are 1 album, in UK 6000 streams are 1 album, Germany Zero and France Zero.
Premium streams mean in US 1250 streams, UK 1000 streams are 1 album, Germany 2000 are 1 album and France 1500 are 1 album.
US and UK ad supported services also include YouTube Video Free Streams as well as Spotify Ad Supported Streams.
Originally posted by britneyliam View Post
I don't know the rules in other countries, but in the UK it isn't eligible to chart until the a physical version is released.

redpajama_set_name: RedPajamaCommonCrawl


looks nice. expensive. is lacking atmosphere.
Non smoking pub, with a courtyard for the smokers. Toilets are a bit grotty. Not cheap. The McMullen AK is still on and was in reasonble condition.
Nice and cosy, good food and great selection of wines.
Sort of place I'd be happy to take my Mum and Dad to as part of a shopping spree down the Old Town.
Only critiscism is it could be bigger (to accomodate more people) and the fruit machine may give it a good income but it looks out of place.
Darts has been replaced by Tapas....thank god!
Does anyone know if they still play darts in there and also do they still sell McMullen AK?
Now converted to 2Dry - very expensive but a full range of wines and lovely Erdinger beer complete with nice courtyard in the back!
A typical old pub with locals. This pub is the place to come for a quiet night watching them all play darts. They have regualr games of darts in there. I think but and not sure, theya re the only pub in the old town which serve up Hertfordshires McMullen AK Ale. Its lovely too. The staff have always been friendly and as longs as your not loud the locals will not look at you.


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In the interests of persevering indigenous knowledge of seed saving and seed banking. The SAFSC is committed to sharing information and details of organisations that are practicing seed saving and seed banking. Should you wish to list your seed bank kindly email info@safsc.org.za your details.
Below is an example of a seed bank being built by the farmers from Ilizwi Lama Farmers Union in the Eastern Cape.


Monkfish partners up magnificently with this punchy sauce. Served on a homemade roti, this recipe is a winner.
For the monkfish, break the cardamom pods and the mace flower. Place them into a heavy-based frying pan and dry-fry over a low heat for 2-3 minutes.
Place the cardamom, mace and the remaining ingredients, except the monkfish, into a food processor and blend until smooth.
Place the monkfish into bowl and pour over the marinade. Cover with clingfilm and chill in the fridge for 6-8 hours, or overnight.
For the roti, place the flour into a bowl and gradually add the water, beating well to form a firm dough. Tip the dough out onto a floured work surface and knead for a couple of minutes until smooth. Cover the dough with clingfilm and set aside to rest for two hours.
Tear off walnut-sized pieces of dough and roll them out thinly to a diameter of 12.5cm/5in.
Heat a frying pan until very hot and fry the dough for 1-2 minutes on each side (or until bubbles appear on the surface).
Remove the roti from the pan with a pair of tongs and carefully hold it over a gas flame until puffed up. Repeat with the remaining dough.
For the sauce, heat a wok until hot, add the oil, garlic, ginger and chilli and fry for 1-2 minutes until just coloured.
Add the onion and cook for 2-3 minutes stir in the tomatoes and cook for 4-5 minutes until softened. Add the cream and return to a simmer.
Heat a griddle pan until very hot, add the monkfish and griddle on each side for one minute until just cooked through. Then add the monkfish to the sauce and season, to taste, with salt and freshly ground black pepper. Finally, stir in the coriander.
Place the roti onto the plate then spoon over the monkfish and sauce.


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For Admissions to Reception, parents and carers need to apply online to Walsall Council.
Please ensure that you have read our admissions policy below:
Admissions Policy 2019-20
Proposed Admissions Arrangement for 2020-21: Click here
In the light of the measures advised by the Government in response to the outbreak of the coronavirus, Criterion 2 of the school's Admissions Policy (Regular worship within the Parish of Aldridge) will not apply whilst public worship across the Parish has been suspended. When calculating whether an application for admission satisfies this criterion, the governors will not include in the calculation the weeks in which it has not been possible for anyone to take part in public worship.
http://cms.walsall.gov.uk/index/education/school_admissions/primary_school_admissions.htm
General School Admissions
All parents who wish to send their child to Cooper & Jordan should contact us and request an application form. On receipt, you will be advised if there are any places available. Cooper & Jordan admissions policy will determine which children are admitted and each application will be "ranked" against this policy, details of which are available on the links below. Parents of pupils who are not allocated a place may appeal through the standard procedures. Details of this are available from the school or from the admissions department. The school published admission number (PAN) is 60 per year group. However, because we are a voluntary aided school, our Governors may allocate up to 64 places per year group in Key Stage 2. These are at the discretion of the Governors and Head Teacher. Children are admitted to Reception classes in the September of the academic year during which their fifth birthday falls.
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Pupils may be admitted into the school nursery at the start of the academic year during which their fourth birthday falls. Each pupil gains admission for either 15 or 30 hours per week (Monday to Friday). There are a limited number of full-time (30 hour) places available subject to eligibility. - Please contact school to express your interest for a places.
Nursery times are 8.45 am – 11.45 am and 12.30 pm – 3.30 pm. The admission number is 52 per day. To apply, parents should complete a Cooper & Jordan application form. Each application will be ranked against our admissions policy when allocating places. Gaining a place to our Nursery does not automatically make your child eligible for a place in Reception. Nursery pupils will need to re-apply as per above.


In a game that was contested in the nastiest of conditions underneath the Thursday night lights, the Whitley County Colonels overcame a muddy, sloppy field to defeat the North Laurel Jaguars in London, 7-0. The win snapped a three-game losing skid for the Colonels, and improved them to 2-4 on the year, 1-0 in district play, ahead of a home game against Perry County Central next week.
On Friday, the Corbin Redhounds surprised no one when they dominated visiting McCreary Central on Homecoming Night, 50-0. The Hounds are now 5-1, 1-0 and will host Jackson County next week on a special Hall of Fame Night.
The Lynn Camp Wildcats also came out on top in a game they were favorites to win Friday, defeating visiting Clinton County 35-14 to stay perfect on the year at 6-0. The Cats will open up district play next week when they host the Pineville Mountain Lions.
The Williamsburg Yellow Jackets were off this week, but they too will open up district play next Friday when they host the Harlan Green Dragons.
Be sure to pick up the October 3 print edition for more details.