Industry news

Date: Jul 13, 2012

July 13, 2012: Peregrine Details Plans For Liquidation; Banks’ Libor Costs May Hit $22Bn; Let Sellers Of The LME Beware

The trustee for exploded brokerage Peregrine Financial announces the liquidation plan for the company; along with that news, there are plenty more updates, developments and commentary on PFG in the newsletter. Continuing liability analysis of the LIBOR scandal suggests banks might pay out more than $20 billion in related settlements and fines. Not all is happiness and rainbows regarding the sale of the London Metal Exchange to HKEx; more than one industry participant expresses concern over the possibility that well-established and efficient transaction conduits could be negatively affected by a transfer of ownership.

First Read

All Those Red Flags   

With each new story about PFGBEST and Russell Wasendorf, Sr., new red flags are springing up. In yesterday’s story from Bloomberg we found out a bunch of PFG employees were taken on a trip to Italy where they stayed at luxury hotels.

Then there is the jet, and the $18 million corporate compound built after the financial crisis caused interest rates to plummet along with trading volumes.

There is the social climbing, along with the expensive celebrity sponsorships at FIA and CME Group events. There is the expensive glossy “vanity” magazine which cost $100,000 a month just to print, Russ Jr. once told me.

The sole practitioner accountant working from a home office is a nice touch and a genuine red flag.

The cake topper is the P.O. box for the bank statements, which is so confounding as to be mind boggling.

Yep, more red flags are blowing with each new story about Wasendorf Sr.

As I mentioned in another commentary, Wasendorf, Sr. was notorious for suing brokers who tried to take their customer business with them to their new firms. If you think about this, it falls into place. He did not want to lose customer seg funds – not because of the lost commission potential, but for other now obvious reasons.

The really scary thing about this part though is that this legal history goes back 10 years or more, as I recount various conversations with brokers over the years. I want to know how far this fraud went back. I expect the truth to come out.

Spending a lot of money on litigation should be a red flag. There should be a reason for it, one that makes economic sense.  

Spending a lot of money on marketing, as PFG did through SFO, event celebrity sponsorships and endless CNBC commercials, should be a red flag. If I had asked any of my brokerage employers over the years to spend this kind of money, I would have been taken away in a white jacket. It is just too far off the charts not to be a red flag.

There are all kinds of red flags, some we know well, some that are new. I am just tired of this industry missing those red flags and learning those lessons the hard way.

~John J. Lothian


At Peregrine Financial, Signs of Trouble Seemingly Missed for Years
It was a triumphant moment in 2009 when a delegation of Iowa lawmakers visited here to tour the gleaming, new headquarters of the Peregrine Financial Group. “This is impressive,” Charles E. Grassley, the Republican senator from Iowa, said, admiring the futures trading firm’s state-of-the-art facility. “This is a company that’s on the top of things.” Today, the only impressive thing about Peregrine is the depth of its problems.
**JK – Quote of the day from Chuck Grassley.


The curious case of Iowa broker’s Romanian property empire
Reuters via Yahoo! News
Russell Wasendorf Sr., the founder of failed Iowa brokerage PFGBest, had risky investments a long way from the Midwest markets where he built his name.
**JK – The Romania connection.


How To Define Your Terms In 300 Pages
New rules governing the swaps market highlight the risks behind sprawling, complex regulatory initiatives. When rules get too complicated, lawyers and lobbyists are the main audience.


The Worst Banking Scandal Yet?
The scandal over the manipulation of Libor has the potential to become one of the most costly and consequential in the history of banking. If the financial institutions involved want to prevent it from overwhelming their businesses and damaging the broader economy, they’ll have to act fast.
**JK – Interesting factoid –  “If Libor was understated by an average of only 0.1 percentage point for a year, the discrepancy on the roughly $300 trillion in interest- rate swaps outstanding at the time would add up to $300 billion.”


Financial System Is Safer, but Not Safe Enough: Former FDIC Chair Sheila Bair
Yahoo! Finance: The Daily Ticker
The latest stain on the world of trading and finance is still darkening, but once again it appears that millions of dollars in customer funds have been misappropriated. This time it’s Iowa-based futures broker Peregrine Financial Group / PFGBest, which dealt another blow to investor confidence after over $200 million of customer money couldn’t be accounted for.
**JK – Why is Sheila Bair not the head of a U.S. super regulator?


Seven ways to clean up our banking ‘cesspit’
By Martin Wolf – Financial Times
The Libor scandal has nailed the coffin of the banks’ reputations shut. After a huge financial crisis and a long list of scandals, banks are now viewed as incompetent profiteers run by spivs. Such disgust over what Paul Tucker, deputy governor of the Bank of England, has called a “cesspit” is quite natural. But disgust alone must not shape reform. Here are my seven suggestions of how best to respond.


Newedge to Join Forces with Thales Trading Solutions
Newedge, a global leader in multi-asset brokerage and clearing, announced today its cooperation with Thales Trading Solutions, a newly created, non-guaranteed Introducing Broker based in New York City. Newedge will provide its full range of best practice multi-asset trading and clearing services to clients introduced by Thales.


Letter from Nadex CEO Commenting on PFG Regulatory Actions
In light of the recent news regarding the regulatory actions and bankruptcy filing by our FCM Member firm Peregrine Financial Group, Inc. (“PFG”), we felt it was appropriate to provide our Members with a statement regarding the situation. All PFG customer funds on deposit with Nadex are held by Nadex in fully segregated accounts at Nadex’s bank. Those funds, which represent a very small portion of PFGBest’s total customer segregated funds, will be held by Nadex until disbursement is directed by the regulators and the bankruptcy court. All PFGBest customer positions at Nadex expired on Monday July 9 and PFG has no remaining open positions at Nadex. Nadex incurred no loss as a result of its relationship with PFGBest.


Lehman Comes Back From the Dead
In the glory days before its collapse in September 2008, Lehman Brothers Holdings was the fourth-largest investment bank in the nation, headquartered in its own 32-story skyscraper on Manhattan’s Seventh Avenue with a block-long electronic billboard that flashed a promotional video night and day. Today the offices of Lehman Brothers are tucked away on two floors in the Time & Life Building, half a block away, where about 430 workers labor to unwind derivatives trades and sell illiquid assets that helped bring the firm down.


Spencer must lead ICAP to its promised land
By Jonathan Guthrie – Financial Times
Michael Spencer, chief executive of interdealer broker ICAP, is an entrepreneur. The great thing about entrepreneurs is that they are enthusiastic. You could get quite carried away yourself, listening to Mr Spencer talking up a forthcoming revamp to ICAP’s EBS foreign exchange trading platform as “a big event that will shake people up in the forex market and give us a big increase in market share”.
**JK – So Michael Spencer is Moses? Interesting visual.

Charlotte Crosswell Talks About The New NASDAQ OMX NLX
The interest rate market will get some more competition at the end of the year with the launch of the NASDAQ OMX NLX futures exchange. JLN editor-in-chief Jim Kharouf spoke with exchange CEO Charlotte Crosswell, at IDX 2012 in London, about the new exchange’s move into euro and sterling-based short-term interest rate and long-term interest rate contracts, the trading and clearing platform and who will be participating in the new market.

JLN Interest Rates

Bonds or Gold?
Ben Garber of Moody’s Analytics Capital Markets Research Group
Low interest rates and threats from inflationary monetary policies challenge the outlook for fixed income investments, increasing interest in alternative assets that can serve as hedges to traditional financial securities. But such investments carry considerable risks. Gold, a classic in this regard, has a record of highly volatile returns, and attracts a very speculative investor base. Furthermore, we believe that the economic fundamentals do not support the case for higher inflation, which is one of the scenarios that would boost gold’s attractiveness relative corporate debt.

Gold’s fortunes shift wildly

Gold has outperformed other investment classes by a wide margin in recent years. Demand has been fueled by rapid emerging market growth, new financial instruments, economic uncertainty, and inflationary fears. Since the end of the 2001 U.S. recession, the price of gold has risen by 20 percent yearly from less than $300 per ounce to its current value of around $1,600. This remarkable climb has reversed decades of poor returns, with 3 percent average annual losses in the twenty years ending in 2000. The surge by gold has lifted its historical average return to 11 percent–surpassing the 9 percent average for the Barclays US Investment Grade Corporate Bond Index (Figure 1). But gold’s boom-bust cycles bring uncomfortable levels of risk. Gold’s 27 percent standard deviation of yearly returns far outstrips the 9 percent range for corporate bonds. Such frequent large losses on gold holdings leave deep holes for investors to recover from, which belies the metal’s reputation as a store of value.

**CN: According to Garber, the release this week of the minutes from the Federal Reserve’s June policy meeting further solidified the attractiveness of fixed incomes over gold. He said the minutes were a mild negative for gold because the Fed does not seem to be as “on the verge of QE3” as some had anticipated. This would be a positive for the dollar and positives for the dollar tend to be a negative for gold.


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Lead Stories

Peregrine Details Plans for Liquidation
The trustee overseeing Peregrine Financial Group Inc. on Thursday outlined plans for the liquidation of the failed U.S. brokerage, seeking court permission to run the business and retain some staff. Ira Bodenstein, the trustee, lodged an emergency motion to operate the business “on a limited basis,” and retain 57 employees to ensure an “orderly” liquidation.

Banks’ Libor costs may hit $22bn
By Brooke Masters in London and Alex Barker in Brussels – Financial Times
Twelve global banks that have been publicly linked to the Libor rate-rigging scandal face as much as $22bn in combined regulatory penalties and damages to investors and counterparties, according to Morgan Stanley estimates.

Let sellers of the LME beware
By Jack Farchy in London – Financial Times
Everyone is over the moon about the sale of the London Metal Exchange to Hong Kong Exchanges & Clearing for almost £1.4bn, right? Not quite: as Sir Brian Bender, LME chairman, revealed in a letter to shareholders this week, one of the LME’s 12 board members voted against the idea of selling the 135-year-old exchange.

Geithner Questioned Libor Process In 2008: Report
U.S. Treasury Secretary Timothy Geithner questioned the integrity of the Libor rate-setting process as far back as 2008, the New York Times reported Friday, citing documents seen by the newspaper.

What Geithner Could Have Done
By Matthew Zeitlin – Newsweek
The Treasury secretary was head of the New York Fed in 2007 and 2008, and if he knew about LIBOR falsification, could have told banks to stop, or referred the matter to the Justice Department and Commodity Futures Trading Commission—which could then have investigated, experts say.

Fed slated to release Libor documents
Market Watch
The New York Fed is slated on Friday to release documents about problems with a global benchmark interest rate during the financial crisis as the controversy swirls on both sides of the Atlantic.

Analysis: Spain’s new austerity buys some time, not solution
Reuters via Yahoo! News
Spain may have won some time with markets and praise from Europe but it has little left in the locker to avoid a state bailout as a new 65-billion-euro austerity program could deepen the country’s economic woes rather than solve them, analysts say.

EC tests Thomson Reuters remedies
By Philip Stafford – Financial Times
European regulators have allowed competitors and customers of Thomson Reuters to test potential remedies offered by the financial data provider to settle an antitrust probe, raising hopes that the end of the three-year case is in sight. The European Commission has allowed rivals such as Bloomberg and Fidessa to test the proposals to open up the availability of some data to investors and rivals in real time. Resolution would help Thomson Reuters avoid a potential fine.

PFGBest Collapse

Peregrine probe eyes accounts in Iowa
By Gregory Meyer and Kara Scannell in New York – Financial Times
Investigators probing the alleged fraud at futures broker Peregrine Financial Group are intensifying their focus on a customer account held at a small town branch of US Bank where more than $200m is missing.

PFGBest chief: Prickly Iowa hero met stiff welcome in Chicago
By Ann Saphir and P.J. Huffstutter | Reuters
Russell Wasendorf Sr., the founder and CEO at failed futures brokerage PFGBest who now stands accused of a massive fraud, has a giant smile and a jeweled pinky ring, a private jet and a temper. “You could have not sent me a more clear message of the low regard you hold me and my firm,” Wasendorf wrote in a letter, dated October 20, 2000, to Jack Sandner, a former chairman of the Chicago Mercantile Exchange. “I guess I should have taken the hint when you refused to take my phone calls or when you refused to write a foreword in my latest book.”

Commodities Corner: PFGBest debacle riles commodity futures industry
Market Watch
Commodity traders have seen their fair share of action this year, but now must also face growing concerns over the integrity of futures trading in the wake of the latest regulatory investigation.

Brokerage Scandal Shakes Small Iowa Town
Russell Wasendorf Sr. put Cedar Falls, Iowa, on the financial-industry map when he moved the headquarters of his futures brokerage to the farm-belt city from Chicago in 2009. Now, his attempted suicide and the alleged fraud that triggered the collapse of his business have put the little city of 39,000 on the map of big financial scandals and cast doubt over the future of the business and philanthropic endeavors that gave Mr. Wasendorf an outsize presence here.

How PFGBest Differs From MF Global, Lehman
The bankruptcy of brokerage PFGBest will likely be much different from those of the parent companies of other brokerages, including Lehman Brothers Holdings Inc. and MF Global Holdings Ltd., and not just because those firms are so much larger.

Ah, the ‘Self-Regulated’ U.S. Futures Markets — How’s That Going For You, CME Group?
CME Group lost ground Tuesday after brokerage firm Peregrine Financial Group announced terrible news: Peregrine’s owner Russell Wasendorf Sr. attempted suicide and left a note saying he’d done something wrong, reports the Financial Times It has since filed for liquidation.


Q&A with CFTC Chairman Gary Gensler
Time Magazine
Gary Gensler, chairman of the U.S. Commodities Futures Trading Commission, is an ex-banker whose job it is to rein in other bankers. Part of an original group of financial reformers including Sheila Bair and Elizabeth Warren, he’s still fighting the good fight in Washington, most recently nabbing Barclays Bank for interest rate rigging in the LIBOR scandal, an ongoing investigation involving as many as 20 major banks.

Investors warn EU hedge fund rules could hit other funds
Reuters via Yahoo! Finance
Leading fund management firms have warned the European Commission’s head of financial regulation that new rules aimed at tightening practice at hedge funds could damage the rest of the industry’s ability to operate effectively.

NFA Signs Agreement with Phoenix Partners Group to Provide Regulatory Services to Phoenix’s Swap Execution Facility
National Futures Association (NFA) and Phoenix Partners Group LP today announced that they have entered into an agreement that paves the way for NFA to perform regulatory services for Phoenix’s swap execution facility (SEF). Phoenix Partners Group is a New York-based derivatives broker.

Exchanges & Trading Facilities

Direct Edge Sale Speculation Shows TMX Group’s U.S. Ambitions
Direct Edge Holdings LLC, the operator of U.S. equity exchanges based in Jersey City, New Jersey, is a candidate to become the first American equity market controlled by a foreign company.

Maple and TMX Group Provide Update On Upcoming Milestones
* TMX Group shareholders urged to immediately tender their shares to the Maple offer before it expires at 5:00 pm (Eastern) on July 31, 2012
* Maple to be renamed TMX Group Limited on August 10, 2012

NYSE Euronext (NYX) today announced a strategic partnership with Equilar, the leader in executive compensation and C-Suite mapping technology, to provide NYSE and NYSE MKT issuers access to Equilar Atlas, a comprehensive solution to help identify executive and board member candidates for potential hire and to maximize business networking opportunities.

EPEX SPOT and EEX advocate a market-based, European and holistic power market design
The European Energy Exchange AG (EEX) and EPEX SPOT SE intensively participate in the debate on the European market design and on the implementation of the energy turnaround in Germany – most recently in the framework of their comment on the expert report entitled “Studies regarding a futureoriented design” prepared by the Institute of Energy Economics at the University of Cologne (EWI) on behalf of the German federal government.

ROFEX Modifies Its Membership Scheme – A New Regulation That Benefits All Market’s Brokers
After its demutualization in 2006, as from which it is no longer necessary to be a shareholder to trade in the market, ROFEX places itself again at the forefront of Argentine markets by modifying its membership scheme. Memberships will be transferable as from August 1, 2012.

AgroGeneration launches successful bond issue on NYSE Alternext

Méthanor lists on NYSE Alternext

Program Trading Averaged 30.3 Percent of NYSE Volume during July 2-6

Warsaw Stock Exchange: 400 Companies Listed On NewConnect

Hedge Funds & Managed Futures

Commodity Falls Spark Investor Rethink
Emiko Terazono, Financial Times
It feels like the 2008 rollercoaster all over again for commodities investors. Prices of commodities from oil to copper have fallen sharply. Money is flowing out of the sector and some investors are questioning the so-called commodities ‘supercycle’ – the mantra that prices will rise and rise, underpinned by Chinese growth.

Bloodied but unbowed, hedge fund Merchant Commodity trudges on
Reuters via Yahoo! Finance
Unlike some of his peers, Michael Coleman is not throwing in the towel after a bruising 18 months during which his Merchant Commodity Fund lost two-thirds of its capital.

Meridian Fund Services Wins Best North American Hedge Fund Administrator in Hedgeweek USA Awards 2012
Business Wire via Yahoo! Finance
Meridian Fund Services wins “Best North American Hedge Fund Administrator” at the Hedgeweek USA Awards 2012 and is profiled in today’s Hedgeweek Special Report.

Oxford Uni’s endowment boosted by private equity
Reuters via Yahoo! News
Oxford University’s endowment fund avoided the big losses that left other investors reeling from the euro-zone debt crisis last year, after the centuries-old seat of learning put more money into private equity.

Hedge Funds Are Better For Their Managers Than Their Customers
Business Insider
Forget the one percent denounced by the Occupy Wall Street protesters. Hedge-fund managers have made so much money for themselves that they are in the top percent of the one percent. The billions they have raked in make bankers’ bonuses look titchy.

Rating Action: Moody’s Downgrades Italy’s Government Bond Rating To Baa2 From A3, Maintains Negative Outlook

Banks & Brokers

Exclusive: Vanguard weighs push into banking
Reuters via Yahoo! News
Vanguard Group is considering offering more banking services, the U.S. mutual fund leader said, at a time when asset managers may need new ways to hold on to clients’ cash if proposed rules shrink money market funds.

Analysis: Fallout from JPMorgan loss may have just begun
Reuters via Yahoo! News
Jamie Dimon will do his best to put the “London Whale” trading flap behind him on Friday when JPMorgan Chase & Co reports earnings, telling Wall Street that the bank has capped losses from the bad trades and found the key risk management flaw behind the positions.

JPMorgan’s ‘London Whale,’ Two Bosses Leave Bank, WSJ Reports
The JPMorgan Chase & Co. employee known as the ‘London Whale’ and two of his supervisors from the chief investment office have left the bank, the Wall Street Journal reported, citing people it didn’t identify.

Barclays’ Diamond turns to top lawyer for Libor scandal
Reuters via Yahoo! News
Barclays’ embattled former chief executive Bob Diamond is being represented by top white-collar defense lawyer Andrew Levander in a widening scandal over the manipulation of benchmark interest rates, people familiar with the matter said.

Wells Fargo, Libor Defense, Tax Legislation: Compliance
Wells Fargo & Co. , the largest U.S. mortgage lender, will pay $125 million and set up a $50 million assistance fund to settle U.S. allegations that it discriminated against minority borrowers.

Ex-Bankers Are Charged With Fraud
Four former top executives of a failed Virginia bank were charged with fraud, a rare federal criminal case against bank chiefs arising from the recent financial crisis.

Credit Suisse Hires Sherman to Manage Large Hedge-Fund Relationships
Dow Jones
Credit Suisse Group AG has hired Neil Sherman as a managing director in its “Key Account Management” group to handle a number of the bank’s largest hedge funds and other client relationships.

Goldman scales down prime brokerage business in Japan: sources
Reuters via Yahoo! News
The head of Goldman Sachs Group Inc’s prime brokerage unit in Japan will depart by the end of July as the Wall Street bank scales back that operation, which services hedge funds, and shifts some staff and operations to Hong Kong, sources with knowledge of the matter said on Thursday.

Goldman Sachs Said to Hire Former Geithner Aide Williams
Goldman Sachs Group Inc. , the fifth- biggest U.S. bank by assets, hired Andrew Williams, a former U.S. Treasury Department spokesman, for its corporate communications unit, said two people familiar with the matter.

Goldman Sachs Appoints Steven Barg Southeast Asia IBD Co-Head
Wall Street Journal Blogs
Goldman Sachs has appointed Steven Barg as its co-head of investment banking for Southeast Asia based in Singapore, according to a memo seen by The Wall Street Journal.

Morgan Stanley’s Shields Stepping Down at Public Finance
Stratford Shields will step down Sept. 1 as head of Morgan Stanley ’s public-finance department, which ranks in the top four among U.S. municipal underwriters, according to Michael Heaney, global head of credit.

CIMB Hires Former BofA ECM Banker Aaron Lamshed
Wall Street Journal Blogs
Former Bank of America Merrill Lynch equity capital markets banker Aaron Lamshed will join CIMB Group in August as a director based in Sydney, Australia, a person familiar with the matter said.

RBS Asks Court to Block $1 Million Bonus to Former Risk Chief
Royal Bank of Scotland Group Plc asked a London court to approve a decision to block a 700,000- pound bonus awarded to its former head of corporate risk solutions before his dismissal.

A Barclays split would only resurrect Lehman
CNN Money
A breakup of Barclays would essentially bring Lehman Brothers back from the grave, sending Wall Street in the wrong direction.

Clearing & Settlement

CME Group Clearing Advisory
GEX Options Expiration Operational Procedures for Qualified Traders and Clearing Members (OR) Effective Friday, July 13, 2012


NYSE Technologies Expands Network To Equinix New York Data Center Campus – New NY5 facility, Opening August 1, Will Provide Customers With Direct Access To Secure Financial Transaction Infrastructure

Environmental & Energy

Energy industry gets the answers it wanted in CFTC’s swap definition
A few may have wanted regulators to delay it forever and some questions were left unanswered, but it’s hard to argue that the highly anticipated swap definition the US Commodity Futures Trading Commission approved this week was anything but a major victory for the energy industry.

**RKB — Big Energy and Big Environment unite on this one. More below.

US environmental markets dodge Dodd-Frank swaps bullet
Environmental Finance
US environmental commodities such as green certificates and carbon credits will not be classified as swaps under the Dodd-Frank Act, in a move hailed by environmental markets advocates.

Stanford’s George Shultz on energy: It’s personal
Stanford Report
George Shultz leads a group preparing to propose a federal tax on carbon to slash U.S. greenhouse gas emissions and oil consumption, a seemingly unlikely policy from a Republican Party statesman.

**RKB — In case anyone forgot, Shultz and entrepreneur Tom Steyer, a Democrat, were leaders in the defeat of Prop 23.

NYMEX Authorized To Take Disciplinary Action Over GreenX Market Participants


In China, Discomfort Over Inspecting the Inspectors
New York Times
In recent months, China has made it harder for American investors to check the legitimacy of their Chinese investments.

SGX extends India access with 16 July Nifty Options launch
Singapore Exchange (SGX) is offering SGX S&P CNX Nifty Options from 16 July 2012. This latest product partnership between SGX and National Stock Exchange of India (NSE) enhances offshore investors’ access to the Indian economy.

MAS Reprimands Evia Capital Partners Ptd Ltd For Breach Of The Securities And Futures (Licensing And Conduct Of Business) Regulations (CAP. 289, Regulation 10)

Thai Bourse Holds Annual Contest To Enhance Youth Financial Literacy

Shanghai Stock Exchange High Beta And SSE Low Beta Indices To Be Launched

Frontier Markets

The Egyptian Exchange (EGX) Monthly Statistical Report June 2012
Total number of listed companies on the main market amounted to 212 at the end of June 2012. Meanwhile, the number of listed companies on Nilex reached 21 at the end of June 2012.


Workers, bosses disagree on value of performance reviews
By Kristin Samuelson – Chicago Tribune
Ninety-four percent of chief financial officers surveyed in a recent survey by temporary specialized staffing firm Accountemps said formal evaluations are either somewhat or very effective in helping employees improve their performance. But employees surveyed in an accompanying survey had a markedly different perspective: 31 percent of surveyed workers said the appraisals are either somewhat or very ineffective.


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Disclaimer: The John Lothian Newsletter, JLN Environmental/Energy, JLN Metals, JLN Managed Futures, JLN Interest Rates, JLN Options and JLN Forex newsletters and blogs and MarketsWiki, MarketsReformWiki and are products of John Lothian News, a division of John J. Lothian & Company, Inc. The opinions expressed in all John J. Lothian & Company, Inc. publications are strictly those of their respective editors. They are intended solely for informative purposes and are not to be construed, under any circumstances, by implication or otherwise, as an offer to sell or a solicitation to buy or trade in any commodities or securities herein named. Information is obtained from sources believed to be reliable, but is in no way guaranteed. No guarantee of any kind is implied or possible where projections of future conditions are attempted. Security futures are not suitable for all customers. Futures and options trading involve risk. Past results are no indication of future performance. Nothing on any John J. Lothian & Company site should be considered an endorsement by any sponsor of any website or newsletter content.

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