Saturday, March 17, 2018

The Eightfold Path of the Legendary Trader

Like many traders, I read Market Wizards as a kid. If you don’t know it, it’s a collection of interviews with the most legendary traders of the 1980s.

Market Wizards

Back when I first read it, I really had no idea what the hell I was doing. I read it, thought I got it and moved on.
But I didn’t get it.
The reason was simple. I didn’t have the life experience and wisdom to understand it. That would take many, many more years.
A few months ago I picked up my old, dog eared and highlighted copy and started thumbing through it. I expected to snag a few quotes and move on but pretty soon I found myself hooked, reading it cover to cover all over again.
Two things struck me immediately.
  • First, I’d highlighted all the wrong things.
  • Second, I saw instantly how much these men were alike.
No matter where they came from or how they got started, they all remembered one devastating loss early in their career. They all started with little to no idea what they were doing. All of them transcended false beliefs and developed an amazing ability to adapt and change their minds in a flash.
Their styles, politics and temperament all varied widely but the rest of their lives followed a remarkably similar path.
That’s when I realized I was seeing something bigger, a meta-pattern, a pattern of patterns.
Call it the journey of the great trader.
So what is that path and how can you follow it?
Let’s take a close look.

Number One: Start Out Clueless

No matter how good anyone gets at something they always start out clueless. Maybe trading is some innate gift but that doesn’t matter at all at first. Everyone starts at step one.
Nobody starts off a superstar.
Maybe it’s my fault

This Wizards excerpt from Michael Marcus is typical of most traders.
“Q: Did you know anything at all about what you were doing? Had you read anything about commodities or trading?
A: No, nothing.
Q: Did you even know the contract sizes?
A: No, we didn’t.
Q: Did you know how much it was costing you per tick?
A: Yes.
Q: Apparently, that was about the only thing you knew.
A: Right. Our next trade, in wheat, didn’t work either. After that, we went back to corn and that trade worked out better; it took us three days to lose our money. We were measuring success by the number of days it took us to lose.”


You see the same story again and again. Somebody hears about how they can get rich quick in the market. Their friend tells them or they read a story about some king of Wall Street or the newly crowned crypto rich and they leap in hoping to make a quick buck, their eyes filled with stars.
Even if they do have some idea about the basic rules, like setting good stops and choosing a position size that won’t wipe them out they almost always ignore it.
Paul Tudor Jones, a super aggressive, hard charging trader, tells the tale of a horrible early trade where he made a spur of the moment “macho man” cotton buy leaving him seriously vulnerable. Immediately the other pit traders knew his mistake and he did too. The big whale of the cotton market started dumping on him almost instantly, driving the price down hard and locking him in.
He learned the hard way “Never play macho man with the market” as he wiped out 70% of his equity in a single trade.
Every single person thinks they’re smarter than the market. Even if they read the time honored rules of the best of the best they’re thinking “those don’t apply to me, I’m different.”
And that takes us to step two.

Number Two: Make the Same Mistakes as Everyone Else

Think you’re immune to making the same mistakes everyone else does?
You’re not. But don’t worry, you’re in good company.


Nobody is immune.
Inevitably new traders don’t understand why the rules are there to protect them even if they know the rules. Maybe after their clueless stage they read a few books or listen to some smart sounding traders on Twitter or take a course.
The problem is they don’t really understand what they’re reading and hearing. They can’t process it yet because they don’t have the experience to see the wisdom in it, even if they understand it partially at the intellectual level. Knowledge can’t be passed on passively. It has to be earned through personal experience.
And when you don’t understand the rules, what happens?
You screw up.
And what are some of those rules?
1) Don’t overtrade.
2) Keep your position sizes small.
3) Set stop losses.
4) Don’t make snap decisions.
5) Don’t get too high or too low emotionally.
Those are just a few of the essential pearls of wisdom that every trader eventually figures out.
Eventually.
The hard way.
In the beginning everyone just glosses over them.
Legendary currency trader Bruce Kovner tells a classic story about snap decisions. Kovner made his original money hedging spreads on contracts. He’d be long one contract and short another to reduce the risk but as soybeans rocketed to new highs in the 1970’s his broker got caught up in the euphoria and called him wild with greed:
“Soybeans are going to the moon…You are a fool to stay short the November contracts. Let me lift your November shorts for you, and when the market goes limit-up for the next few days, you will make more money.”
He agreed. Limit-up is a circuit breaker on the markets. If they went too high or too low the contracts locked and nobody could trade them. You were stuck. Limit-up meant you were making the absolute most money possible. Limit-down? You were losing the most money possible and even worse you were stuck and you couldn’t sell out.
Kovner perfectly describes the crazy euphoria every early market apprentice feels:
“It was a moment of insanity. Fifteen minutes later, my broker calls me back, and he sounds frantic.
‘I don’t know how to tell you this, but the market is limit-down! I don’t know if I can get you out.’ I went into shock. I yelled at him to get me out.”
By sheer luck he managed to get out when the markets ticked up past limit-down for a few minutes but not before eating a massive loss.
Afterwards, Kovner talks about the sickness every trader feels when they make a horrific trade and the market eats them alive.
“I was up about $45,000. By the end of the day, I had $22,000 in my account.”
And that brings us to our very next step on the journey of trader enlightenment.

Number Three: Take a Big Loss

Every single trader will eventually experience a catastrophic, heart breaking loss. Many of the best traders went completely belly up, more than once. The original great speculator, Jesse Livermore, lost multiple fortunes.


Kovner tells us the gut wrenching sickness of losing big money in the market.
“I went into emotional shock. I could not believe how stupid I had been — how badly I had failed to understand the market, in spite of having studied the markets for years. I was sick to my stomach, and I didn’t eat for days. I thought that I had blown my career as a trader.”
Michael Marcus tells a similar story of a disastrous sugar trade.
“Q: How much did you lose on the trade by the time you liquidated?
A: I lost my own $30,000, plus $12,000 of the $20,000 my mother had lent me. That was my lesson in betting my whole wad.”
Every trader has a story like that to tell. For me it was NEO. I got in late in the bull run and bet big. I just knew it was going to the moon and a few days later I was riding high and I nearly doubled my money.
China started threatening the big exchanges. It seemed every single weekend there was a brand new story attacking crypto, a big banker saying it was worthless or insane, China cracking down, or another country looking to ban trading.
It didn’t take long for the markets to panic.
And there was no worse coin to hold at the time than a Chinese coin. That’s exactly what NEO was, red Chinese through and through.
I watched my wins vaporize over the course of two days and I just froze. I panicked. I liked the coin and the project, I thought it would turn around so I just hung on as it went down and down and down.
In the end I lost 68% of what I put in.
I was sick to death. I couldn’t sleep or eat for days. Working out didn’t help. Getting a massage didn’t help. Alcohol didn’t help. Whacking it didn’t help. Nothing helped.
Only one thing could fix it. The next step.

Step Four: Reflect and Come Back Stronger

Once you finally experience that soul crushing loss it’s not long after that you realize it was the absolute best experience of your trading life.


If you’re smart and you’re focused you start looking at everything you did wrong. You go over it with a fine tooth comb. You question all your beliefs and ideas. No longer are you willing to just take things at face value. You want to know what works and what doesn’t and so you finally get serious.
Paul Tudor Jones remembers reflecting on his mega-loss and getting so depressed he wanted to quit. But then it hit him:
“It was at that point that I said, ‘Mr. Stupid, why risk everything on one trade? Why not make your life the pursuit of happiness rather than pain?’
That was when I first decided I had to learn discipline and money management. It was a cathartic experience for me, in the sense that I went to the edge, questioned my very ability as a trader, and decided that I was not going to quit. I was determined to come back and fight.”
Real loss equals real wisdom.
Without that loss none of the lessons make any sense to you whatsoever. You’ll think you’re different and that the rules don’t apply to you.
But they do. They apply to everyone. No exceptions.

Step Five: Learn the Age Old Lessons the Hard Way

What is it about the human mind that makes us learn all our lessons the hard way? We read the great wisdom of the ages and promptly ignore it.

Be like water, my friend.

Maybe that’s just the meaning of life? We all have to go through the same struggles and make our own mistakes and live the great story again and again.
After my big NEO loss I reflected on everything I’d done wrong and it hit me like a diamond bullet between the eyes. I realized I didn’t know how to make decisions when I was under fire. I just froze like a deer in headlights. I knew the market had turned and that NEO was going down and I should get out but I couldn’t pull the trigger.
Internally, I just couldn’t accept the loss. I was in denial. I was a good trader and careful or at least I thought I was but now I was faced with a new reality.
I wasn’t as good as I thought I was. And I couldn’t accept the reality in front of me. I couldn’t put it behind me and move on.
I should have sold that NEO shit stack long before it cost me a big chunk of change. Instead I road that loser all the way into Hell instead of cutting my losses.
As Tudor Jones says “losers average losers.”


People love to hang onto losers. They love the pain. Oh they won’t admit it but they do. Pain is drama. And people love drama.
Either that or they imagine the market merely lost its mind for a minute. The project is a good project. Things will turn around.
Except more often then not they don’t turn around or they turn around too late and because you held so long you can’t make up that loss.
And it doesn’t matter if gold is good or a company is good or a project is good. Sometimes that doesn’t mean a damn thing to the market and it just tanks. Saddling up that bomb and cowboy riding it to the bottom is always a disaster.
NEO taught me the most important lesson of all.
More importantly I now understood the lesson:
“Cut your losses, let your winners run.”

Step Six: Money Management

The ancient wisdom really boils down to two words: Money management.
Cutting losses is one of those key principles that everyone has to learn. It’s not enough to simply trade the market, you have to know you’re going to get things wrong a lot of the time. And that means you have to protect your money at all costs.
That’s just basic probability.
Paul Tudor Jones says “I am always thinking about losing money as opposed to making money…I have a mental stop. If it hits that number, I am out no matter what.”
Money management comes down to a few critical principles:
1) Keep your position sizes small to minimize risk
2) Ruthlessly cut your losses.
3) Always use stops.
4) Don’t use too much leverage
5) When you start losing, start trading smaller.
6) When you go on a bad streak, get out of everything and take a break.
7) If you get in a bad trade, get out immediately because you can always get back in later.
All of these principles work in tandem to protect your money.

Don’t throw good money after bad

I learned this the hard way yet again just the other day, when I went a little too heavy on a leveraged position after a strong winning streak.
The mistake was easy to see in retrospect.
What blinded me at first was that I’d gotten masterful at setting my stops. One of my tricks is to set a limit stop price far above or below the trigger so it always gets filled. I’d never had a stop not fill and I’d never gotten liquidated. I don’t get liquidated because I use just enough leverage to make a difference but not enough that the market would only have to move a few percentage points to kill me off.
I put in my trade, set my stop and went to bed.
When I woke up in the morning and checked in I saw I was down 29%. My stop never triggered. I wasn’t liquidated because I hadn’t over-leveraged but it didn’t matter.
I was sick to my stomach.
So what did I do?
Number two, ruthlessly cut loses.
After a few minutes of feeling sorry for myself and thinking I should hold on because maybe it would come back I shut that stupid voice up and sold. I cut that loss immediately. I took it and moved on.
That’s when I understood once more that all the principles work together in concert.
If the position size had been smaller the overall loss would have been smaller. But because I hadn’t used too much leverage I hadn’t gotten liquidated so I was still very much protected.
Low leverage, small positions and stops all work as one. Sometimes one of these risk management tools fail you and the others kick in to help. It’s like the seat belt and the airbag.
Sometimes the seat belt isn’t enough but the airbag is there to save you.

Step Seven: Stop Following Others

It may seem strange to say that I don’t follow other traders or the news but I don’t follow any of them anymore. I may occasionally glance at a chart of a trader who I really respect and see if it matches with my sense of the market but it’s incredibly rare. I might also check in with a trader who I know well and who’s had success over the long run.
And then I just do what I want anyway.

You can go your own way.

In the end you have to follow your own light.
You have to get so good that you trust your own analysis above all else. When you make a mistake you need to know you’re strong enough to figure out what it was and fix it the next time.
If you’re meant to be a good trader you will be. It’s as simple as that.
Ed Seykota is one of the best traders profiled in Wizards. He says is best:
“It is a happy circumstance that when nature gives us true burning desires, she also gives us the means to satisfy them.”
If you have that burning desire to trade and to win, you’ll find a way and you won’t need to follow anyone else once you get your feet wet.
I have my school of traders but my main lesson to them is simple. Learn from me and then move on. Become your own master. Don’t sit at the feet of gurus your whole life.
As for the news? Nothing but poison. Turn it off as fast as you can.
I highly, highly recommend every single human being take a news fast for a month. Disable anything related to news on your phone feed. Unfollow everyone on Facebook. Don’t read the Twitter stream. Get a site blocker for when you’re working and use it frequently.
I guarantee you, you will not miss out on anything. If something really, really big happens you’ll hear about it because people will talk about it. If it’s not big enough to be on everyone’s lips it’s not worth hearing about.
Here’s another thing I guarantee. You will be mentally, emotionally and spiritually healthier by an order of magnitude. Your anxiety will decrease as will your confusion and fear.
You’ll probably end up extending the news fast indefinitely. I know I did.


I could care less about Google News or which coin some random person on the Internet thinks is going to the moon tomorrow based on astrology and hope. Probably the last time I followed news was during the China crisis. And if I had to do it all over again, I wouldn’t read a word of it this time. I do occasionally read one magazine that I like with strong, consistent journalism but even that is less and less frequent, maybe once a month or every few months and mostly because there is one story I want to read in depth.
When you give up on the news you’ll be in fine company.
Ed Seykota said “eventually I became more confident of trading with the trend and more able to ignore the news. I became more comfortable with the approach.”
I have not met a single good trader who is a news junky even though the average trader is a hopeless news junky. They want a reason for the market to go up or down. They can’t face that it’s random chaos and the push/pull of a billion emotional monsters.
So writers come up with a good reason for why the market made a move. Interest rates changed. A trade war looms. A big soybean shortage struck. Some of these are probably factors but it’s really impossible to use that news in any effective way 99% of the time. The other 1% of the time it is but so what? Is it really worth watching 99% white noise to get that?
Even worse, news is about conflict and tragedy. It’s about pain and suffering. It’s about extraordinary events.
But the more you watch it the more you think those extraordinary events are normal events.
Plagues happen every day. People get shot up around the corner every few seconds. A baby is butchered every ten minutes in your town.
If you’re born in an insane asylum and everyone is screaming all the time you think it’s normal.
It ain’t normal.
You’re hearing about statistical outliers and it does nothing but warp and derange your mind.
The news is poison.
Bite your arm, suck that venom and spit it out for good.

Step Eight: Develop Your Own Style

If you make it this far, you’ve come to the final step on the journey of trading mastery.
What’s that?
Develop your own system.


I used to study Kung Fu. I noticed that most people were obsessed with lineage. Who was the great master that taught their great master in an unbroken line over five hundred years? Did the system change? Was it passed down perfectly and directly?
I soon realized this kind of thinking was total madness. Of course the system changed. Each master learned new lessons through his own life experience and added that to the system. It he didn’t, he was no master. In fact, he probably sucked horribly if he just photocopied what his teacher taught him and passed it down to you.
And I also found myself thinking about the first person in that line of legendary martial artists. If you go back far enough, eventually you get to someone who started the system. That brings up one inevitable question:
Who taught them?
The answer is obvious.
Nobody.
They taught themselves.
And that is what the absolute best of the best do in all fields. They don’t follow. They create.
The old Kung Fu masters didn’t just learn from someone else and regurgitate it. They took what they learned and modified and improved it. They studied nature and themselves. They watched the movement of snakes and birds and they tried to tease out the secrets of those animal powers. They wanted to move as fast as a snake and strike like a tiger. They had everything they needed by observing the world around them.
You must become the master. When you get there you’ll find there’s nobody handing out a belt. You’ll be the final judge in your journey.
And that means eventually you’ll need to develop a trading style that perfectly fits your own personality, your own strengths and weaknesses. If you’re just following someone else’s picks blindly you won’t have to strength to stay in a trade when the going gets really rough. That kind of confidence only comes from within.
To do that you’ll have to look deep inside and figure out what you really want from the world.
As Ed Seykota says, “Everyone gets what they want out of the markets.”
Some people like to lose. Some people like to play the Martyr. Some folks like to be popular. Others love to be contrarians and bet against the crowd. Still others like to sound smart at parties. But they don’t like to make money. They might even think it’s dirty or evil and they self sabotage.
Whatever your weakness the market will happily feed it to you. If you love the excitement of winning big and then losing it all and making it back again, you’ll get that too.
Ed went further: “I think that if people look deeply enough into their trading patterns, they find that, on balance, including all their goals, they are really getting what they want, even though they may not understand it or want to admit it.”
But the best traders do want to make money. They have a deep passion for the markets and a burning desire to win. To do it they all come to the same understanding eventually by reflecting deeply and transcending their own human limitations to become the best of the best.
And when they do they’re ready to walk their own path, a lonely path, but a joyous one too:

Yoda from The Empire Strikes Back

The path of the master.
They no longer need to read any more books or listen to anyone else or follow anyone else’s star.
They become their own guiding light.
They live and die by their own decisions. When they win they don’t get too high. When they lose they don’t blame anyone but themselves.
And they don’t need any outside validation or praise or judgement.
That’s because after all that time and effort and suffering, they finally knowwhat they’re doing. It’s not arrogance. It’s an internal compass that is unflinchingly accurate, developed only through dedication, perseverance, persistence and passion.
It’s earned over time. A long time. Nothing else can give it to you.
It can’t be bought, bargained for, or cheated. There are no short cuts and there never will be.
And all the praise and validation the legendary trader will ever need will show up in the only place that matters.
Their bank account and crypto wallet.
https://hackernoon.com/the-eightfold-path-of-the-legendary-trader-11b304db97c2 

Sunday, March 11, 2018

Why tariffs and import taxes are a stupid idiotic idea

Import taxes of any kind are a stupid idea, we will succinctly explain why.  Until this idea, Trump has had a fairly good track record if judged only by the correlation to the stock market.  The import tax is the first major mistake, and shows that he really doesn’t understand international finance and has not been able to hire a decent advisor to explain him that the world has changed in the last 50 years.  We explain this and more in our ground breaking work Splitting Pennies. 
Trade Wars are not a new thing in fact they’ve been a tool of state sponsored mercantilism since the beginning of time; tax or ban foreign goods in order to spur the domestic economy.  There’s a small problem though.  The world is today completely intertwined, interconnected, and intermingled.
Did you know, that Budweiser, a company which is more American than apple pie, is owned by InBev, a Belgian company?  Did you also know that of the 15 Budweiser breweries outside of the United States, 14 of them are in China?  So what does that make Budweiser – American, Chinese, or European?
forex
Regarding the car industry, nearly every Asian manufacturer makes cars right here in USA.  Kia, Hyundai, Toyota, the list goes on and on.  So we all know that Toyota is Japanese.  Or is it?  Land Rover is British, but it was bought by Ford, a US publicly traded company (F).  Ford’s most complex robotic factory is in Brazil.  Ford operates in nearly every country in the world, and their business is sustained by a sophisticated foreign exchange operation managed on their treasury desk.  Ford notoriously hired Muslims, Blacks, and other workers that had trouble finding jobs at other companies.  Who owns ford now is a global mix of citizens from every country in the world, foreign governments, and you can rest assured municipal pension funds, state pension funds, all own a piece of this American icon (F).  So what is American, anyway?
Trump’s heart is in the right place, the idea of rebuilding USA’s manufacturing base, creating jobs at home, reducing ‘offshoring’ – should be a priority of America first and it makes economic sense.  But the way to accomplish it is not through import taxes or to start a trade war.  Companies like Apple (AAPL) need to be incentivized in other ways to move their factories from China to Kansas.  Grants, tax incentives, government if then contracts (for example if Apple moved its phone manufacturing to USA the government could require USG employees to use iPhone for Security reasons.)  Or another solution, we can cut the military budget in half, and instead of building missiles and bombs, we can build technology parks in places like Kansas where there is plenty of cheap land.  We can build factories and retask soldiers to do non-military functions like planting trees or building the useless wall with Mexico.  We should invest in robotic factories and state of the art design organizations, like they have in Europe and Korea.  Farming can be hydroponic and automated.  There are thousands of ideas, and thousands of people who have thousands of ideas and who are capable of implementing them.  But we are not listening to those people, or supporting them.  USA has plenty of natural resources, real estate, and most importantly business innovation motivation to act as a natural global incubator for global business.
Instead of import taxes we should incentivize more foreign businesses to move here, such as by creating foreign ‘tax havens’ like Delaware, and providing privacy to foreign entities who would otherwise go to Switzerland or the Cayman islands.
The tax reduction plan was a huge win for Wall St. and Main St.  The idea of import taxes is the opposite.  We should encourage business growth not stifle it.  There are other more intelligent ways to spur the domestic economy.  We explain this and more in our ground breaking work Splitting Pennies. 

Sunday, March 4, 2018

T’my coin – a great idea from Russian history

(Bloc10.com 3/4/2018) — During the period of Russian History known as the “Mongol Invasion” foreign Khans (rulers) imposed taxes based on a financial system calculated by male conscripts to the army.  The mongols imposed a military system of economy where everything was looked at from the perspective of the military.  When a town’s taxes were calculated, they cared not about money but how many able men could serve in the Khan’s army.  Although merchants still paid taxes in the form of money (similar to our ‘sales tax’) towns, provinces, and other municipalities such as the grand duchy of Nizhni Novgorod paid their taxes in soldiers, roughly 5% of the total population.
With new Cryptocurrencies lacking novel ideas for backing, one only needs to look at Medieval European history for many practical examples.  Why should all Cryptos be tied to the electronic world?  In fact the opposite needs to happen, if Crypto is going to move beyond the high tech crowd.  New Cryptos need to have real world purposes, serve multiple economic use-cases, that fit aptly like a puzzle piece into the existing model.  The idea of Cryptocurrency is security and efficiency, not to reinvent the underlying business model.  Ultimately, the financial services sector should be like a utility that allows the real sectors to grow and innovate.  What has happened in the last 50 years has been the opposite, Wall St. has become an industry by itself, charging fees and taxing real industry and stifling growth.
At Bloc10 we are innovators and developers, not principals.  We want to develop your Blockchain project as a vendor and allow you to grow your business naturally (organically).  Ideally, you won’t even notice that we exist!  It’s your project.  Grow your business, and Get Bloc.
Photo taken from George Vernadsky’s “A History of Russia”

Wednesday, February 28, 2018

Staff Letter: Engaging on Fund Innovation and Cryptocurrency-related Holdings

January 18, 2018

Paul Schott Stevens
President & CEO
Investment Company Institute
1401 H St., NW, Suite 1200
Washington, DC 20005
Timothy W. Cameron
Asset Management Group – Head
Securities Industry and Financial Markets Association
1101 New York Avenue, NW, 8th Floor
Washington, DC 20005
Re: Engaging on Fund Innovation and Cryptocurrency-related Holdings
Dear [Mr. Stevens/Mr. Cameron]:
As you know, the U.S. investment fund market is one of the most robust, varied and successful markets for investment products in the world. Its success can be attributed, in significant part, to the commitment of fund sponsors to responsible innovation and continuous improvement of the products they offer. This commitment is especially important because many of America’s Main Street investors rely on registered funds to help them build toward education, retirement and other important goals.
Flexibility to innovate is also a key feature of the Investment Company Act of 1940. As the Division with primary responsibility for regulatory policy regarding registered funds, we seek to foster innovation that benefits investors and preserves the important protections that Congress established in the 1940 Act. Over the years, dialogue between fund sponsors and the Division has facilitated the development of many new types of investment products that have expanded choice for investors. Exchange-traded funds and money market funds are notable examples.
Recently, the growth in cryptocurrencies and cryptocurrency-related products has attracted significant attention, and we have seen interest among sponsors in offering registered funds that would hold these new digital products. As we have in the past, the Division stands ready to engage in dialogue with sponsors regarding the potential development of these funds. We believe, however, that there are a number of significant investor protection issues that need to be examined before sponsors begin offering these funds to retail investors.
We appreciate that proponents of cryptocurrencies and related products have identified a range of potential benefits. We are also aware that critics of cryptocurrencies have raised various concerns regarding transparency of information, trading, valuation and other matters related to the nature of the underlying assets. In addition, the innovative nature of cryptocurrencies and related products, as well as their expected use and utility in our financial markets, means that they are, in many ways, unlike the types of investments that registered funds currently hold in substantial amounts. In light of these considerations, we have, at this time, significant outstanding questions concerning how funds holding substantial amounts of cryptocurrencies and related products would satisfy the requirements of the 1940 Act and its rules. To facilitate the start of our dialogue, we have identified below a number of these questions, and we invite you and any interested sponsors to engage with us in detail on these. While we have identified the questions below, we note that the cryptocurrency markets are developing swiftly. Additional questions may arise from these developments.[1]

Valuation

Mutual funds and ETFs must value their assets on each business day in order to strike a net asset value (“NAV”). Appropriate valuation is important because, among other things, it determines fund performance, what investors pay for mutual funds and what authorized participants pay for ETFs (and what they receive when they redeem or sell). Would funds have the information necessary to adequately value cryptocurrencies or cryptocurrency-related products, given their volatility, the fragmentation and general lack of regulation of underlying cryptocurrency markets, and the nascent state and current trading volume in the cryptocurrency futures markets?
How would funds develop and implement policies and procedures to value, and in many cases “fair value,” cryptocurrency-related products?
How would funds’ accounting and valuation policies address the information related to significant events relevant to cryptocurrencies? For example, how would they address when the blockchain for a cryptocurrency diverges into different paths (i.e., a “fork”), which could result in different cryptocurrencies with potentially different prices? How and when would funds recognize such information in their NAV?
What policies would a fund implement to identify, and determine eligibility and acceptability for, newly created cryptocurrencies offered by promoters (e.g., an “air drop”)? How might a fund account for those holdings if the fund chooses to claim such cryptocurrencies?
How would differences among various types of cryptocurrencies impact funds’ valuation and accounting policies?
How would funds consider the impact of market information and any potential manipulation in the underlying cryptocurrency markets on the determination of the settlement price of cryptocurrency futures?[2]

Liquidity

A key feature of open-end funds, such as mutual funds and ETFs, is daily redeemability. Funds must maintain sufficiently liquid assets in order to provide daily redemptions. Under the new fund liquidity rule, rule 22e-4, funds will be required to implement a liquidity risk management program.[3] Under the rule, among other things, funds must classify their investments into one of four liquidity categories and limit their investments in illiquid securities to 15% of the fund’s assets.[4] A fund’s liquidity classifications should be informed by the market depth of its holdings (that is, whether trading varying portions of a position in a particular portfolio asset is reasonably expected to affect the liquidity characteristics of that investment) as well as other relevant market, trading and investment-specific considerations.
What steps would funds investing in cryptocurrencies or cryptocurrency-related products take to assure that they would have sufficiently liquid assets to meet redemptions daily?
How would funds classify the liquidity of cryptocurrency and cryptocurrency-related products for purposes of the new fund liquidity rule, rule 22e-4? For example, would any of these products be classified as other than illiquid under the rule? If so, why? How would funds take into account the trading history, price volatility and trading volume of cryptocurrency futures contracts, and would funds be able to conduct a meaningful market depth analysis in light of these factors? Similarly, given the fragmentation and volatility in the cryptocurrency markets, would funds need to assume an unusually sizable potential daily redemption amount in light of the potential for steep market declines in the value of underlying assets?
How would a fund prepare for the possibility that funds investing in cryptocurrency-related futures could grow to represent a substantial portion of the cryptocurrency-related futures markets? How would such a development impact the fund’s portfolio management and liquidity analysis?

Custody

The 1940 Act imposes safeguards to ensure that registered funds maintain custody of their holdings. These safeguards include standards regarding who may act as a custodian and when funds must verify their holdings. To the extent a fund plans to hold cryptocurrency directly, how would it satisfy the custody requirements of the 1940 Act and relevant rules? We note, for example, that we are not aware of a custodian currently providing fund custodial services for cryptocurrencies. In addition, how would a fund intend to validate existence, exclusive ownership and software functionality of private cryptocurrency keys and other ownership records? To what extent would cybersecurity threats or the potential for hacks on digital wallets impact the safekeeping of fund assets under the 1940 Act?
While the currently available bitcoin futures contracts are cash settled, we understand that other derivatives related to cryptocurrencies may provide for physical settlement, and physically settled cryptocurrency futures contracts may be developed. To the extent a fund plans to hold cryptocurrency-related derivatives that are physically settled, under what circumstances could the fund have to hold cryptocurrency directly? If the fund may take delivery of cryptocurrencies in settlement, what plans would it have in place to provide for the custody of the cryptocurrency?

Arbitrage (for ETFs)

ETFs obtain Commission orders that enable them to operate in a specialized structure that provides for both exchange trading of their shares throughout the day at market-based prices, and “creation unit” purchases and redemptions transacted at NAV by authorized participants. In order to promote fair treatment of investors, an ETF is required to have a market price that would not deviate materially from the ETF’s NAV. In light of the fragmentation, volatility and trading volume of the cryptocurrency marketplace, how would ETFs comply with this term of their orders?
Have funds engaged with market makers and authorized participants to understand the feasibility of the arbitrage for ETFs investing substantially in cryptocurrency and cryptocurrency-related products? How would volatility-based trading halts on a cryptocurrency futures market impact this arbitrage mechanism? How would the shutdown of a cryptocurrency exchange affect the market price or arbitrage mechanism?[5]

Potential Manipulation and Other Risks

In a recently issued statement, Chairman Jay Clayton noted that concerns have been raised that cryptocurrency markets, as they are currently operating, feature substantially less investor protection than traditional securities markets, with correspondingly greater opportunities for fraud and manipulation.[6] The Commission has also discussed concerns relating to the risk of fraud and manipulation in cryptocurrency markets in orders denying exchange proposals to list the shares of commodity trusts that would hold cryptocurrency.[7] In addition, a number of recent media reports have highlighted a range of possible vectors for potential manipulation of cryptocurrency markets. Although some funds may propose to hold cryptocurrency-related products, rather than cryptocurrencies, the pricing, volatility and resiliency of these derivative markets generally would be expected to be strongly influenced by the underlying markets.
How have these concerns informed your responses to the foregoing questions concerning, for instance, valuation and liquidity?
How would you weigh these concerns in considering whether offering a proposed fund is appropriate for the wide range of investors, including retail investors, who might invest in the fund? Would investors, including retail investors, have sufficient information to consider any cryptocurrency-related funds and to understand the risks?
Have you discussed with any broker-dealers who may distribute the funds how they would analyze the suitability of offering the funds to retail investors in light of the risks discussed above? Are there particular challenges investment advisers would face in meeting their fiduciary obligations when investing in cryptocurrency-related funds on behalf of retail investors?
* * *
The resolution of many of the questions we have raised in the context of a product seeking to register under the 1940 Act will also be important to the ongoing analysis of filings for exchange-traded products and related changes to exchange listing standards by the Division of Corporation Finance, the Division of Trading and Markets and the Office of the Chief Accountant. In addition, questions concerning what regulatory structure or structures apply to the market for the underlying instrument will be relevant to the requirements of both the 1940 Act and the Securities Exchange Act of 1934, including applicable accounting, audit and reporting implications. We have been and will continue working closely with the other Divisions and Offices as we analyze these significant issues.
The preceding questions have focused on specific requirements of the 1940 Act and its implications for registered offerings of funds intending to hold cryptocurrency or related products. There may be registered offerings under the Securities Act of 1933 by entities holding similar products and pursuing similar investment strategies. Those entities would have to comply with the registration and prospectus disclosure requirements of the Securities Act.
Until the questions identified above can be addressed satisfactorily, we do not believe that it is appropriate for fund sponsors to initiate registration of funds that intend to invest substantially in cryptocurrency and related products, and we have asked sponsors that have registration statements filed for such products to withdraw them. In addition, we do not believe that such funds should utilize rule 485(a) under the Securities Act, which allows post-effective amendments to previously effective registration statements for registration of a new series to go effective automatically. If a sponsor were to file a post-effective amendment under rule 485(a) to register a fund that invests substantially in cryptocurrency or related products, we would view that action unfavorably and would consider actions necessary or appropriate to protect Main Street investors, including recommending a stop order to the Commission.
I appreciate your assistance in sharing our views on this subject with your members. We look forward to engaging with you and your members on these important questions, and we invite you to contact Barry Miller at (202) 551-6725.
Sincerely,
Dalia Blass
Director
Division of Investment Management
U.S. Securities and Exchange Commission

[1] This letter addresses issues arising from funds potentially focused on cryptocurrency-related products. We note, however, that other types of digital assets and related products could present similar issues.
[3] See Investment Company Liquidity Risk Management Programs, Inv. Co. Act Rel. No. 32315 (Oct. 13, 2016), available at https://www.sec.gov/rules/final/2016/33-10233.pdf.
[4] The 15% illiquidity standard is consistent with past Commission statements regarding funds’ liquidity standards. However, the Commission’s new rule strengthened the compliance controls under the standard, including requiring reporting to a fund’s board and to the Commission regarding breaches of the 15% illiquid limit. Most funds would be required to comply with the new rule’s liquidity risk management program requirements on Dec. 1, 2018, while fund complexes with less than a $1 billion in net assets would be required to do so on June 1, 2019.
[6] SEC Chairman Jay Clayton, Statement on Cryptocurrencies and Initial Coin Offerings (Dec. 11, 2017), available at https://www.sec.gov/news/public-statement/statement-clayton-2017-12-11.
[7] See, e.g., Securities and Exchange Commission, Order Disapproving a Proposed Rule Change (Mar. 28, 2017), available at https://www.sec.gov/rules/sro/nysearca/2017/34-80319.pdf.

http://www.sec.gov/divisions/investment/noaction/2018/cryptocurrency-011818.htm


https://www.sec.gov/divisions/investment/noaction/2018/cryptocurrency-011818.htm 

Monday, January 29, 2018

These Are The 6 Traders Who Were Just Arrested For Manipulating The Gold Market

On Monday morning we reported that a number of traders - currently or formerly employed by UBS, HSBC and Deutsche Bank (as usual, no JPMorgan US banks were touched) - would be perp-walked and charged in an unprecedented cross-agency crackdown between the CFTC, DOJ and FBI seeking to punish spoofers of futures. This was confirmed moments ago by a CFTC press release which announced criminal and civil enforcement actions against three banks and six individuals involved in commodities fraud and spoofing schemes.
Here is what got far less publicity: it wasn't just any futures that were spoofed - all the banks and traders busted were charged for spoofing the precious metals market, i.e. gold and silver. We bring this up because there are still the occasional idiots out there who say gold and silver were never manipulated.
The banks in question, and their penalties:
Deutsche Bank will pay a $30 million civil monetary penalty and undertake remedial relief. The Orders finds that "from at least February 2008 and continuing through at least September 2014, DB AG, by and through certain precious metals traders (Traders), engaged in a scheme to manipulate the price of precious metals futures contracts by utilizing a variety of manual spoofing techniques with respect to precious metals futures contracts traded on the Commodity Exchange, Inc. (COMEX), and by trading in a manner to trigger customer stop-loss orders."
UBS will pay a $15 million civil monetary penalty and undertake remedial relief.  The Order finds that from "January 2008 through at least December 2013, UBS, by and through the acts of certain precious metals traders on the spot desk (Traders), attempted to manipulate the price of precious metals futures contracts by utilizing a variety of manual spoofing techniques with respect to precious metals futures contracts traded on the Commodity Exchange, Inc. (COMEX), including gold and silver, and by trading in a manner to trigger customer stop-loss orders."
HSBC will pay a civil monetary penalty of $1.6 million, and cease and desist from violating the Commodity Exchange Act’s prohibition against spoofing, after an Order found HSBC engaged in numerous acts of "spoofing with respect to certain futures products in gold and other precious metals traded on the Commodity Exchange, Inc. (COMEX). The Order finds that HSBC engaged in this activity through one of its traders based in HSBC’s New York office."
For those keeping count, this is roughly the 4th time HSBC has been found guilty of manipulating markets after the bank nearly lost its charter and swore it would never manipulate markets again.
* * *
And here are the 6 traders who spoof and otherwise manipulated the precious metals market:
  • Krishna Mohan
The CFTC today announced the filing of a federal court enforcement action in the U.S. District Court for the Southern District of Texas against Krishna Mohan of New York City, New York, charging him with spoofing (bidding or offering with the intent to cancel before execution) and engaging in a manipulative and deceptive scheme in the E-mini Dow ($5) futures contract market on the Chicago Board of Trade and the E-mini NASDAQ 100 futures contract market on the Chicago Mercantile Exchange.
  • Jiongsheng Zhao
The CFTC today announced the filing of a federal court enforcement action in the U.S. District Court for the Northern District of Illinois against Defendant Jiongsheng Zhao, of Australia, charging him with spoofing and engaging in a manipulative and deceptive scheme in the E-mini S&P 500 futures contract market on the Chicago Mercantile Exchange (CME).
  • James Vorley & Cedric Chanu
The CFTC announced the filing of a civil enforcement action in the U.S. District Court for the Northern District of Illinois against James Vorley, a U.K. resident, and Cedric Chanu, a United Arab Emirates resident, charging them with spoofing and engaging in a manipulative and deceptive scheme in the precious metals futures markets.
  • Jitesh Thakkar & Edge Financial Technologies
The CFTC today announced the filing of a federal court enforcement action in the U.S. District Court for the Northern District of Illinois, charging Jitesh Thakkar of Naperville, Illinois, and his company, Edge Financial Technologies, Inc. (Edge), with aiding and abetting spoofing and a manipulative and deceptive scheme in the E-mini S&P futures contract market on the Chicago Mercantile Exchange (E-mini S&P).
An amusing tangent: recall that according to court docs related to the prosecution of "May 2010" flash crash scapegoat Navinder Sarao, the former S&P spoofer allegedly asked the abovementioned founder of the trading-software company Edge Financial Technologies Inc. to modify a program to allow him to automate some trading functions.
The CFTC and Department of Justice said in their complaint that those modifications were designed to help him spoof the markets more efficiently.
It gets better: as the WSJ reported, the now arrested Jitesh Thakkar, the founder of Edge Financial and a former member of a CFTC technology-advisory committee, said in an interview that the CFTC had sent [Sarao] a letter asking him to retain all documents related to Mr. Sarao.
“I’ve spoken out against spoofing,” he said. “We didn’t create anything that does anything illegal.”
Two years later Thakkar was arrested for just that, but it also now appears that Thakkar may have used Sarao's algo himself.
* * *
Finally, our old friend, Andre Flotron, formerly of UBS, who as we reported on several prior occasions was arrested and charged with gold-rigging after a lengthy career of doing just that at the largest Swiss bank:
The CFTC announced the filing of a civil enforcement action in the U.S. District Court for the District of Connecticut against Andre Flotron, of Switzerland, charging him with engaging in a manipulative and deceptive scheme and spoofing in the precious metals futures markets on a registered entity.
* * *
Meanwhile, the S&P500 manipulation by the Fed and spoofing by HFTs continues apace, and will as long as the market keeps levitating because it is only when stocks crash, that the fingerpointing begins.

Saturday, January 27, 2018

tZERO ICO About To Make Overstock A Wall Street Favorite

Summary

tZero ICO is about to disrupt markets.
KODAKCoin perhaps the first large company launching a Crypto.
KODAKCoin will trade exclusively on tZERO's platform.
KODAKCoin itself is not important, what is important is this is the precedent for hundreds of other big corporate coins.
It's amazing how many rumors and trash talk can keep a genie in a bottle. But in the next 60 days, not Trump himself could stop this genie from coming out of Overstock.com's (NASDAQ:OSTK) bottle and when it does, it will make Crypto history. There's nothing new here, this story has been going on for some time - but we're now nearing the climax, the singularity. And it's happening now!
Recently, we authored an article talking about how Overstock is the perfect Blockchain play and we still believe it is.
But since our article things have changed for the better, and we want to focus on the tZERO ICO.

Read the full story at: https://seekingalpha.com/article/4140678-tzero-ico-make-overstock-wall-street-favorite

Monday, January 1, 2018

Overstock: The Perfect Stock Blockchain Play

Summary

TZero has been working on this technology for years - it is launching, not developing.
Few legitimate options for stocks that are deep into Blockchain technology.
Alternatives such as IBM are not as pure Blockchain plays as OSTK.
For those of you who are 'now' looking at Blockchain, see this article on Seeking Alpha we authored in March of 2016 urging investors to go long Overstock.com (OSTK) which we did, and profited nicely. Like the whole move with Bitcoin, it would have taken patience to sit and hold through the process, now almost 2 years. Things take time to build, develop, and grow. Now we're on the precipice of what we believe is the 'real' bull run for crypto, that being the regulated run. Until now, there hasn't been really a way to buy or invest in cryptocurrencies or businesses in a regulated way. Now there're futures on regulated exchanges, and the TZero ICO.

Friday, December 22, 2017

Bitcoin as a monetary policy tool

If you look from a systemic perspective, Bitcoin has been nothing more than another electronic asset bubble, while not a QE tool explicitly used by the Fed - it has accomplished the same thing, but much faster.  What took decades and years for QE to do in other markets, Bitcoin did inside of a few months.  While it's true that Bitcoin only goes up because US Dollars (USD) and other fiat currencies buys, the net effect is a near infinite velocity of money.  One subtle problem the Fed has dealt with perhaps more than inflation and others is Velocity of money, which is in steady decline since the credit crisis:
Basically, Velocity of money is how quickly money is 'spent' and moved around the economy.  Trillions of QE money on banks balance sheets is not helpful for the economy.  The Fed knows this, but is limited in its creativity.  Interestingly, if you look at the above chart when Velocity of money was in peak decline, it is about the time Bitcoin was introduced.  We have exposed how we believe anonymous forces inside the US Government are if not completely, somewhat responsible for the creation of Bitcoin, and in the very least participated in the design.  This isn't a conspiracy theory, it is macro analysis.  Who was the most capable group who had the world's best cryptographers, mathematicians, and huge budget? (NSA).  Who had an economic need for Bitcoin to solve the problem of Velocity of money (The Fed).  
Cash has the distinct advantage of being anonymous. You can put cash under your mattress or in a vault, and no one knows about it except you. A national cryptocurrency would make it far more difficult for criminals to hoard money because all transactions would be recorded in the government ledger. If a transaction was deemed illegal, the parties to the transaction could be identified. This is also true with bitcoin, whose ledger is viewable to anyone. Despite the negative press about bitcoin being used for illegal transactions, bitcoin is not anonymous, and criminals who use it often do not understand that their transactions are being recorded.
There is another reason for governments to like the idea of a national cryptocurrency: strengthening the power of monetary policy to help manage the economy.
We published this insight in multiple articles months ago and in our book Splitting Bits: Understanding Bitcoin and the Blockchain.
The WAPO story is clearly setting the stage for something, as WAPO has become the goto CIA mouthpiece for PsyOps and other agencies in "Big Intel." 
That's it, now go spend your Bitcoin!
For a detailed breakdown how the financial system really works, checkout Splitting Pennies.

Splitting Pennies and Splitting Bits

In 2015 we wrote Splitting Pennies to show the world what the FX market really is.  Splitting Pennies is a metaphor, for what the global FX money markets have become.  It is a holistic, systemic overview of the global financial system, with practical examples and pitfalls to avoid.  Since then, Bitcoin has become so popular we conceived Splitting Bits, the logical sequel in the Splitting Finance series.  Now you can get both on Kindle or Paperback from Amazon - See www.splittingpennies.com for more info or go here and buy it.

Saturday, December 16, 2017

What's really driving Bitcoin through the roof

Although Bitcoin is electronic and moves quickly, the real world doesn't.  Since Bitcoin (which is colloquially BTC/USD) has been in the news, millions have decided to put their own money into the Crypto world and press their luck.  So here's what's driving the price.  Let's say you want to buy Golem, it's not offered on Coinbase, you need to first get an account at Bittrex or Cryptopia which are only fundable in Crypto.  That means if you are not a hacker or computer expert, you need to first connect your Coinbase account to your bank account at Wells or BOFA and then buy BTC paying the egregious 7% fee (which ironically is similar to an FX transaction).  Then, and only then, you can fund your Bittrex with BTC and buy XRP or whatever.  So this is driving the price of BTC higher, as there is precious little supply of BTC.  We call this in FX 'real money flows' - as DB noted recently, Japanese men have become 'crypto day traders' - but the real upward pressure is by using BTC as a base/funding currency, which is only beginning.  Crypto exchanges are experiencing huge bottlenecks, which means this squeeze has only started.  This week the price of BTC/USD can run up 100% or more due to this demand.  

That means, millions of people investing thousands of dollars, is driving the price of BTC up, and will likely continue to do so, until there are viable alternatives, which there will be.  Currently BTC is really the only choice for many - although it is slow, inefficient, and feature poor.

Sunday, December 10, 2017

EES: The TRUTH about the new Bitcoin Futures CME contract

Elite E Services 12/10/2017 - As a Forex CTA for 12 years, we were happy to learn the CME will offer a Bitcoin futures contract, and called the CME to learn more.  Unlike most of these Bitcoin outfits, the CME has an office, a phone, which is answered, and we were routed to the correct person.  We don't want to name names as we still wait a response from legal about the publication of information (which will likely not happen before the contract goes live) so we will speak only generally about this contract and comment on what some of the market is saying:

 The problem, of course, boils down to Bitcoin’s volatility, something we flagged after the CME announced circuit breakers early last month.
Having taken a gamble on bitcoin futures, which are set to begin trading by the end of the year, the CME is now seeking to avoid the consequences of what has emerged as both the cryptocurrency's best and worst selling point: its unprecedented volatility…While the CME already uses daily vol limits on most other markets, including crude, gold and market futures, to temporarily halt trading when price swings get out of control, the CME has never before dealt with something like bitcoin
In June, Bloomberg showed how Bitcoin’s 30-day volatility had risen to 100%, which was comparable (at the time) with one of the most volatile financial instruments they (and we) could probably think of - a three-times levered ETF in junior gold miners.

The price of Bitcoin (notably, BTC/USD) has been exploding all week basically with the market expecting that with regulated futures contracts, it will bring institutional money into the Crypto market.  While that may be true, this futures contract is not exactly a conduit, as it is 'cash settled' which means effectively 'not settled' or 'self-cleared'.  CME will match buyers and sellers and not have any connection to any Bitcoin exchange or other clearing facility.  At the end of the day, each contract will have a profit or loss, against each other.  Crypto Market Makers could at their own risk, provide liquidity on-exchange and lay off risk independently, through the exchanges.  But practically, why would they?  Just to soak up 'newbie' liquidity from the moms and pops now able to trade the futures contract through their IRA?  Something certainly doesn't add up here, and given the chaos and volatility we saw all week, we are expecting at best, a total market meltdown; at worst, they may cease trading the contract.  There is certainly a lot of money waiting in the pipeline for the moment the contract goes live.  And it's not the only one, CBOE has a contract too, which is the first one which will go live.

Traders wait in anticipation this week to see how the market will react to the first regulated Crypto contracts.

To get in on the action checkout some Bitcoin resources we've added to our website by clicking here.  If you want to learn more about Bitcoin from the perspective of digital currency, which we've been doing for 15 years, checkout Splitting Bits - Understanding Bitcoin and the Blockchain.