The client, an insider at a publicly listed company, was under investigation by multiple exchanges and the SEC for potential trading misconduct in equity markets. In this case, the client was being investigated for trading in the shares of his own company.

The regulators were concerned with a variety of potential violations of market rules and securities laws, but mostly with alleged “paint the tape” activities and disruptive trading designed to distort prices on an intraday basis. The client needed independent data analytics and economic analyses to present to the SEC.

We assembled a team of financial data specialists and trading experts to conduct analyses of the data, including:

  • Collecting and analyzing large volumes of trading data and market data
  • Interpreting trading documentation and communications
  • Forensically recreating BBO and exchange level order sequences in the context of the client’s trading sequences
  • Creating risk positions and analyzing trade book performance
  • Testing for indicia of market manipulation and price impact of the trading at interest

We compiled this information and submitted expert reports to the SEC. After these reports were issued, the SEC halted its administrative proceeding.