Tag Archives: fraud

Fraud Friday: When Auditors Attack, or Fear & Loathing in Clay County, MO

State auditors tend to embody the excellent advice of President Teddy Roosevelt: They speak softly and carry a big stick. Most state audit shops work under a broad legislative mandate – this includes the ability to examine any and all records of state and local agencies, and this includes subpoena power, when necessary.

In practice, state audit shops rarely threaten to flex their legal muscles, and this is mostly because their legislative mandate and mission are widely understood by public policy makers and managers. When the State Auditor calls, you pick up the phone and give them what they need, so to speak. Now, there are definitely instances where an agency will dig in and try to refuse a specific records request, etc., but that almost invariably ends poorly for that agency. It’s even rarer for an agency to not only refuse to cooperate, but to also engage legal counsel to threaten legal action against the state auditor for even insinuating their intention to audit an agency. And yet, here we are…

For those unfamiliar with the greater Kansas City metropolitan area, Clay County occupies roughly the northeast quadrant of the KC metro. The county’s population is about 250,000 and growing, and it’s a fairly large county geographically, so while Clay County residents are part of a relatively bustling urban midwestern city, the county retains a rural, provincial character. This is attractive for many residents who move there seeking reasonably-priced land, good schools, an increasing number of amenities and retail options, and a sane commuting distance to almost any part of the Kansas City area.

Unfortunately, small-town living also tends to include small-town politics, and things have been getting a bit…testy…up in Clay County recently.

KC television station WDAF “Fox 4 KC” has been conducting an extensive, in-depth journalistic investigation of Clay county commissioners and numerous reports of government waste, fraud, and abuse associated with the county government. In my experience, it is unusual for a local TV news department to devote such a significant amount of resources to a local public policy matter, and I’d like to recognize the excellent reporting of Megan Dillard and the entire Problem Solvers team at Fox 4.

Last year, reports of wasteful spending and poor oversight began surfacing in Clay County. $600 coffee makers. Unexplained $5,000 cash transfers to Paypal.  The hiring of ELEVEN legal firms to conduct legal work on behalf of the county and the commissioners. Procurement card abuse by county management. Failure to follow the approval process for significant expenditures. Managers signing their own expense reimbursements. In other words, the familiar tale that we public-sector auditors too often end up investigating as fraud and turning over to law enforcement for prosecution. WDAF aired their first story about this mess on Feb. 28, 2018, and it’s a doozy:

Missouri Auditor Weighs in on Clay County’s Alleged Misuse of Taxpayer’s Money

This Northland county is facing growing public outrage after slashed budgets, salary increases for elected officials and possible misuse of taxpayer money.

Stop wasteful spending. It`s a message, a mantra, that Clay County citizens have made their battle cry. They’re frustrated by what they see as a misuse of taxpayer money, overspending, lack of internal controls and budget cuts to much-needed county departments.

‘I was just embarrassed by how our county was being run. Enough was enough,’ said Clay County resident Jason Withington. He started the petition drive along with former Clay County employee Sherry Duffett.

We’ve got everything in this story: Arrogant public employees, both elected and appointed, who resent open records requests and do everything they can to avoid accountability? Check!

Ridiculous-seeming expenses, that even if justified, still look terrible on an investigative report on television? Check!

A whistleblower putting their livelihood on the line for coming forward to resist and/or expose the avarice and greed of the villainous county employees? Check!

Clay County residents have noticed all of this alleged malfeasance and are understandably pissed off. Part of their collective response has been to start a petition drive to implore Missouri State Auditor Nicole Galloway’s office to conduct a thorough, comprehensive, non-partisan/non-political audit and investigation of the alleged waste, fraud, and abuse.

There’s a lot more to this story, and I encourage any of you who are interested in good governance and fraud investigation to view and follow the story. However, recent developments in this story have kind of blown my mind. Essentially, Clay County hired an attorney to send threatening letters to both the County Clerk AND THE STATE AUDITOR. That’s right – these local government “public servants” are insinuating that the State Auditor not only has no jurisdiction to conduct an audit or investigation of the county’s books but that even attempting to do so will result in legal action against the State Auditor herself! In addition to the letter to Galloway, the law firm also served whistleblowing Clay County Clerk Megan Thompson with a similarly-worded threatening letter in late March. Needless to say, Galloway ain’t having any of that nonsense.

Days after voicing concerns about the red flags FOX4’s investigation uncovered, Missouri State Auditor Nicole Galloway also received a threatening letter from Pearson…”It is clear there are questionable activities,” Galloway previously said of Clay County spending.

The eight-page letter she received said Galloway’s comments to FOX4 “reflect an inappropriate prejudging of issues based on far less than all the facts,” and her comments “violate the state law that defines the duties of the auditor. Frankly, the comments make clear that you and your office are now incapable of objectively performing an audit or any other activities regarding clay county,” Pearson said in his letter…

…Pearson says Galloway and her office should recuse themselves from such action, not participate in any activities in Clay County, and refer all Clay County matters to an external accounting firm. ‘”t is unfortunate that such measures are necessary to ensure an independent process that complies with state law,” Pearson wrote, “but given the comments on camera, I see no other alternative.”

Pearson gave Galloway 10 days to heed his request. “If you do not do so, Clay County, on behalf of its taxpayers, reserves all rights to take legal action to enjoin any unlawful actions,” he said.

Galloway’s office sent its own letter in which she repeated, “there are legitimate concerns” in Clay County and “citizens concerns appear to be numerous and widespread.” Galloway’s general counsel also said Pearson “mischaracterized” and took the auditor’s comments “out of context.”

“While we could speculate as to your motivations for doing so, this office takes any concern related to these matters seriously,” general counsel Paul Harper wrote.

He added that Galloway’s comments in FOX4’s story “clearly demonstrate that the auditor remains objective and has neither made any predetermined assessment of the facts nor predetermined any recommendations for a future report.”

The letter concludes, “We stand ready to assist any citizens with their concerns about how public funds are handled.” – Fox4KC

That takes some pretty big brass ones to tell a state auditor’s office that they have 10 days to stand down. Elected officials in Clay County are now backpedaling, stating that the law firm in question did not bring the letter before the County Commission for review and approval before it was sent, blah blah blah.

Plausible deniability – The provenance of weasels worldwide! I suspect there will be much more to this story going forward, and we’ll update as things develop.


Music Recommendation: All Them Witches from Nashville, TN. These guys aren’t breaking any particularly new ground, but they definitely ARE producing some groovy, stoned-out, blues-space-rock jams. I particularly dig https://open.spotify.com/embed/track/2EvUjCWg5zeaeKxGeOaHPh“>When God Comes Back, Heavy/Like A Witch, and Elk.Blood.HeartGo ahead, eat an edible or three, and trip out on these spacey sounds. Tip of the hat to my cousin-in-law (I think), Jack Vogel for turning me on to these dudes!

Food Recommendation: Look, it was just recently Easter, and holidays require, nay, they DEMAND high-quality, high-calorie sugary treats. For my (considerable) money, it’s impossible to beat See’s Candies

If they were good enough for Warren Buffet to buy the entire company after trying them, they’re good enough for your broke ass. My personal favorites in the See’s lineup: Milk/Dark Bordeaux, Toffee-ettes, and Butterscotch Squares. As Amy, my lovely & talented spouse says, “They’re just little drops of Heaven.”

Until next time, keep fighting the good fight!


 

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Welcome to the Jungle or, The Taxman Cometh

“It ought to be remembered that there is nothing more difficult to take in hand, more perilous to conduct, or more uncertain in its success, than to take the lead in the introduction of a new order of things” – Niccoló Machiavelli, The Prince


Fraud Friday is coming to you from the long & winding road this week. Accompanying the lovely & talented spouse to a corporate awards event & enjoying a brief respite from the deep freeze of the Central Plains has been a much-needed change of pace.

However, there is no escaping the increasingly-chaotic situation brought about by the recent sweeping changes to the federal tax code. We’ll focus on the implications for increased tax fraud & the deterioration of enforcement capabilities on the part of the regulatory agencies (aka the IRS).

As most of you are surely aware, Congress passed H.R. 1, the Tax Cuts & Jobs Act in late December of last year. While this blog assiduously attempts to avoid discussing the overt political aspects of the legal & regulatory environment, a couple of key developments pertain specifically to those of us in the compliance and investigative universes:

1) Loopholes in loopholes inside loopholes that also contain loopholes

Look, I am FAR from being an expert on tax structuring/avoidance, but minds far greater than mine have pointed out how the new legislation contains enough vague, opaque language to provide decades of billable hours to the tax nerds:

35 pages of Loopholes in the New Tax Law

Of particular concern is the potential for clever manipulation of individual earned income into lower tax rates by creating what are essentially one-person corporations. As explained by Vox:

‘Under the new law, the top ordinary rate on labor income will be much higher than the top rate on corporate income. As a result, many taxpayers will be able to shield a portion of their labor income from tax by setting up a corporation. So Joe Smith, previously an assistant account director for a PR firm, can become Joe Smith, Inc., a new startup company! The firm makes payments to the new corporation instead of to Smith. Thus, Smith shields his labor income from the higher individual tax rate.

The IRS might investigate whether the new corporation pays Smith a reasonable fee for his services, which some tax-law precedents suggest it is obliged to. That’s one check against this tax dodge, and there could be others. But how many new corporations can the IRS investigate? And if Smith can find a few friends to join his new corporation, it will be even harder for the IRS to challenge.” Which brings us to our second point:

2) The IRS is Hosed

It’s no secret that there has been an exodus of the IRS workforce over the past several years. And who can blame them? Years of significant budget cuts, failure to recruit new talent, and a seemingly infinite supply of political contempt for the entity that administers the collection of the vast majority of federal funds.

Predictably, the enforcement rate has plummeted, and academics and tax experts generally agree that the “rate of non-compliance” (i.e. tax cheating) is under-estimated, because it’s common sense that many people who cheat won’t volunteer that information on a survey, and enforcement actions against non-compliers by definition clearly don’t capture the full picture of tax cheating. As for that dreaded staple of American life, the audit, rates have never been lower. From CNBC:

The number of people audited by the IRS in 2016 dropped for the sixth straight year, to just over 1 million. The last time so few people were audited was 2004. Since then, the U.S. has added about 30 million people.

The IRS blames budget cuts as money for the agency shrunk from $12.2 billion in 2010 to $11.2 billion last year. Over that period, the agency has lost more than 17,000 employees, including nearly 7,000 enforcement agents. A little more than 80,000 people work at the IRS.

IRS Commissioner John Koskinen said budget cuts are costing the federal government between $4 billion and $8 billion a year in uncollected taxes.

‘We are the only agency if you give us more people and money, we give you more money back,’ Koskinen said in an interview.”

3) Which leads to Some Unsettling Possible Societal Outcomes

Besides the obvious fact that in order to function, the US gov’t requires revenue, there are additional sociological implications to a steady erosion in the willingness of the populace to pay what they owe. Income taxes are unlike many other forms of taxation in that they rely to a large degree on the voluntary compliance of taxpayers. As that obligation becomes less ingrained in the American psyche, questions arise about long-term societal stability and the underlying fundamental assumptions of our Republic: https://www.vice.com/en_us/article/d33daz/dont-look-now-but-americas-tax-system-may-collapse-soon

It will be certainly be interesting and scary to see how this plays out over the next several years.


Music Recommendations

Gotta go with a couple of classics on this one. Topically appropriate: “You know where you are? you’re in the jungle, baby! And you gonna die!”

And of course: “Let me tell you how it will be. There’s one for you, nineteen for me.”

Food Recommendation

Norman Love Confections. While in Southwest Florida this week, we visited this shop on the urgent recommendation of our Über driver, and we are quite glad we did. All manner of indescribably delicious confections that are also miniature works of art. The chocolate alligator looked absolutely real! A must-visit if you’re in the Ft. Myers/Na-les area, and they ship worldwide.

Until next time, keep up the good fight!

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Fraud Friday – The Revolving Door, or How I Aced My PCAOB Inspection

hero_Big-Lebowski-2017-7Happy Friday! We’re currently working on a post about the practical, legal, and financial considerations surrounding employee theft cases, how to avoid them, and how to deal with them if you are unfortunate enough to have one crash-land in your universe. As noted philosopher Jeffrey Lebowski once said, “Lotta ins. Lotta outs. Lotta what-have-yous.” It’s a complicated subject, and there’s much to discuss.


So, while we work on that post (and do our day job(s)), we have news of a KPMG executive arrested for quite literally “stealing the exam”, which (allegedly) facilitated numerous subsequent malfeasances. Via the Atlanta Journal-Constitution:

Ex-KPMG exec arrested for alleged role in audit fraud scheme

A former leader at one of the world’s largest accounting firms was arrested on Monday as part of a sweeping fraud investigation, according to the Department of Justice.

David Middendorf, of Marietta, was one of six people charged and was the head of KPMG’s Department of Professional Practice, which oversees the training and internal/external quality control of auditing.

Others charged in the indictment reported to Middendorf, including those he allegedly helped hire away from an organization that inspects KPMG. And, as prosecutors allege, a couple of those hires upon their departure downloaded confidential information about what parts of the Big 4 firm would be inspected by that oversight group.

Having that information on which areas would be targeted by inspectors allowed KPMG to clean them up in advance, essentially making inspections useless.

Brian Sweet was an associate director at the Public Company Accounting Oversight Board, or PCAOB, before he was hired away by KPMG.

The PCAOB is a nonprofit with oversight from the Securities and Exchange Commission created after Congress passed the Sarbanes-Oxley Act of 2002, which increased scrutiny on corporations and their financial disclosures, the indictment explains.

Sweet pleaded guilty of giving PCAOB documents to KPMG and acting as a conduit to alert the accounting firm of where they’d be inspected. According to the Justice Department, Sweet has decided to cooperate with prosecutors.

As alleged, these accountants engaged in shocking misconduct — literally stealing the exam — in an effort to interfere with the PCAOB’s ability to detect audit deficiencies at KPMG,” said Steven Peikin, co-director of the SEC’s Enforcement Division. “The PCAOB inspections program is meant to assess whether firms are cutting corners, compromising their independence, or otherwise falling short in their responsibilities.”

Middendorf allegdly used the information to make business decisions and moved resources around to be most efficent knowing what parts of of the company would and wouldn’t be inspected.

“He’s a career professional in the public accounting business. He’s dedicated his life to KPMG and intends to defend himself,” Middendorf’s attorney Gregory Bruch told The Atlanta Journal-Constitution on Wednesday. Middendorf, 53, faces a maximum sentence of 85 years, the Justice Department said.

The years of allegedly gaming the system was pre-empted by one bad year. KPMG got dinged about 2014 with twice as many negative comments by the PCAOB compared to its competitors. To improve their image after that year, KPMG promised bonsuses to teams that performed well when it came time for inspection by the PCAOB. So, “in an effort spearheaded by David Middendorf and Thomas Whittle,” they started in July 2014 to hire Brian Sweet away from the PCAOB to KPMG. Sweet interviewed with Middendorf and others and was offered a job in April 2015. Shortly before his last day at the PCAOB, “Sweet copied various confidential documents from the PCAOB internal newtork” onto a hard drive and took physical papers, the indictment said. Included in what he took was a list of specific divisions PCAOB was planning to inspect at KPMG, which he was asked about during a lunch with Middendorf in his first week at the firm.

Later that week, Middendorf “told Sweet to remember where Sweet’s paycheck came from and to be loyal to KPMG,” according to the indictment.

Days after, Whittle pulled the new employee aside and told him that “he was most valuable to KPMG at that moment and would soon be less valuable,” the indictment said.

Later that day, Whittle emailed Middendorf the list of inspection targets. “The complete list. Obviously, very sensitive. We will not broadcast this,” Whittle wrote, according to the indictment. At the request of his new bosses, Sweet also reached back out to folks at the PCAOB to see what at KPMG was slated for inspection and relayed that back to his bosses. According to the indictment, Sweet recruited Cynthia Holder, a PCAOB employee tasked with inspecting KPMG. Prosecutors allege that while she was being recruited, she would get documents that Sweet requested. Holder was eventually hired and allegedly copied PCAOB documents onto a flash drive.

And like Sweet did with Holder, she kept in touch with a PCAOB employee who funneled her information for 2016 and 2017 inspsections, which was forwarded to Middendorf, the indictment said. Middendorf then ordered “stealth” re-reviews of departments that were set to be inspected, according to the indictment.

In February 2017, Sweet told a high-ranking employee that their group would be inspected by PCAOB. That employee reported the conversation to the KPMG general counsel on Feb. 13, 2017. Middendorf “was separated” from KPMG in April 2017, the indictment said. “These defendants were each meant to be the watchmen of our financial system,” said Manhattan U.S. Attorney Geoffrey S. Berman. He continued: “The defendants who formerly worked for KPMG were vested with the responsibility to audit publicly filed financial statements and issue audit opinions relied upon by the investing public. The defendants who formerly worked for the PCAOB were supposed to help ensure the quality of the work behind those audits. But, as alleged, these defendants chose to cheat the system and to undermine the safeguards put in place to protect investors.”

The revolving door is nothing new, nor in any way exclusive to the PCAOB and the large public accounting firms. In fact, the European Finance Association published (academic access or purchase required) a 2016 study that found a nearly 25% increase in direct hires from financial regulatory agencies and, more importantly, a SIGNIFICANT change in regulated firm managerial strategy immediately following the hire. From the abstract:

The number of top executives with regulatory experience per firm has increased 24% over 2001–15, and hiring is associated with positive average announcement returns and a salary premium. In the quarter after hire, market and balance sheet measures of firm risk decrease significantly and measures of risk management activity increase, especially for hires from prudential regulators, who directly monitor financial firm risk. The absence of this result for unregulated firms and for exogenous shocks to regulatory experience suggests that firms hire ex-employees of their regulators when they perceive a need to reduce risk, consistent with a schooling hypothesis. (Emphasis added)

The KPMG/Sweet/Middendorf case might appear to be an extreme example of revolving-door malfeasance between the regulator and the regulated, but anecdotal evidence points to a higher incidence of such behavior than even pessimistic industry observers estimate. It will be very interesting to see how this plays out for KPMG and the public accounting industry as a whole.

Music Recommendation: Nigel Stanford, Automatica. cool song and a *spectacular* video from late last year. I, for one, welcome our new robot overlords. Worth watching in 4K HD: https://www.youtube.com/watch?v=bAdqazixuRY

Food Recommendation: Caramel apple fried empanada at Taco Bell. DON’T JUDGE ME! Besides, how do you know I’m not one of the Belluminati? Hint: I’m not.


The views of the author are his alone. Any similarity to real tacos, living or dead, is purely coincidental.

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In the Belly of the Beast, or: How I learned to Stop Worrying and Love High-Frequency Trading Algorithms

Things are getting weird(er)

Sure, your money is safe with us...

Sure, your money is safe with us…

As part of my so-called career development plan, I was able to somehow convince my primary employer to sponsor my membership in a local leadership program here in the Greater Kansas City Metroplex.

Part of the curriculum is visiting local businesses of note, and thus recently I found myself in lovely Lenexa, Kansas, preparing to enter one of the single most dangerous places in America: The headquarters of BATS, the electronic stock exchange that allegedly facilitates a great deal of overt and covert fraud perpetrated on you, the honest, hardworking, gun-and-internet-porn-loving American people.

Stay out of Malibu, Lebowski...

Stay out of Malibu, Lebowski…

Beyond the clearly obvious, which is that BATS doesn’t bother to conduct background checks on visitors (or I would never have been allowed in), I noticed a gripping similarity with other spooky places I’ve visited (think Dachau, any midwestern Wal-Mart, etc.) where great evil has occurred/is occurring: The sheer banality of evil. For a stock exchange that regularly has the highest daily trading volume in the world, BATS keeps it real: subdued furniture and finishes throughout, appropriately frumpy/vaguely-hostile receptionist, etc.

Overall, the aesthetic was remarkably similar to what anyone would run across in a mid-size insurance agency in, say, Sheboygan (not to disparage my Wisconsonite friends, I love that place. Go Badgers!) In a way, it’s a reminder that without the fingernail scratches on the walls inside the “showers” or the cast-iron entrance-gate reminder that “Arbeit Macht Frei,” Auschwitz appears to be just another dreary German summer camp.

Anyway, I suppose I should back up a bit. Who/what the Hell is BATS, and why should we care? A fair question…

In a proverbial nutshell, BATS is an electronic stock exchange, one created to replace the “classic” version of a stock exchange, which in the 20th-century collective consciousness is usually pictured as a bunch of angry white dudes in colored jackets screaming prices at each other on a trading “floor.” If you take nothing else from this post, take this: That image and the world it represents is gone. History. Doesn’t exist anymore. Stocks are now traded electronically, utilizing extremely fast computer networks. In addition to many other changes in the equity-trading world, these computer networks and the entities that deploy them are engaged in a hugely complex and opaque struggle to produce obscene profits, through a variety of legal and no-so-legal means.

One of the strategies for creating profit is called High-Frequency Trading (HFT), and it’s pretty much what it sounds like: Using computers to make kajillions of stock trades, in some cases buying and selling millions of shares within microseconds. HFTs hire lots of very smart computer programmers to create HFT algorithms. These algorithms can evaluate an enormous array of input information, on which they then make trading decisions. Everything from market news to weather patterns to trending Twitter hashtags can (and are) used as input for the HFT algos.

In some fashion, this is remotely similar to the way equities have always traded, even when us slow humans made the trading decisions. For example, I see that Google has missed their quarterly earnings projection, and I become concerned that perhaps Google’s revenue and earnings growth in the future is in jeopardy, and I decide to place a “sell” order on my Google stock. Nothin’ wrong with that (unless I had inside info. on the earnings before they were publicly released, and I acted on it in order to benefit financially. That’s called insider-trading, and ask Martha Stewart how that can turn out.)

But the HFT algos go way, way farther than that quaint example. As detailed in Michael Lewis’ excellent new book Flash Boys: A Wall Street Revolt*, The HFT programmers and traders have figured out a plethora of ways to garner information about stocks BEFORE that knowledge is publicly available, thus allowing them to use their blinding speed to execute stock transactions and profit from the information advantage that they have over not only other investors, BUT THEIR OWN CUSTOMERS.  BATS was specifically designed from the ground up as a platform for HFT traders to employ these strategies.

“But wait,” you say; “Isn’t that basically front-running?”:

Front running (noun): The unethical practice of a broker trading an equity based on information from the analyst department before his or her clients have been given the information.

Well, sure. But if there’s one thing that the last ten years of economic history have proven, it’s that ethics and the law are no match for human greed. Besides, this stuff is super-duper complex, and involves a lot of math and computer code, and it’s not like it’s something TRULY criminal and scary, like, you know, a brown person wearing a hoody and acting suspicous.

So it continues to happen, nobody is charged with a crime or goes to jail, the SEC and other regulatory entities don’t really do anything about it, and we all just accept the mafia tax on our investments that involve equities, to the tune of billions of dollars per year. It’s not like any of us earned and need that money or anything…

All of This is Very Interesting, But What Does it Have to do With Your Visit to BATS?

Well, it just so happened that in addition to our tour of BATS headquarters, we were supposed to have a meeting with Joe Ratterman, BATS CEO and until recently, President and Board Chairperson. After our facility tour, and prior to our scheduled meeting with Mr. Ratterman, our group of fifteen watched a short PR video on BATS and engaged in a brief Q&A with BATS CFO Brian Schell.

I think Mr. Schell thought it was going to be a ‘grip and grin,’ softball-type interaction. Luckily, one other person in our group besides myself had read Flash Boys and understood what BATS was up to, and he began to politely, but firmly, question the CFO about BATS and their role in facilitating HFT front-running. Schell acted stunned that anyone would dare to ask that type of question, and proceeded to enter into a long, confusing narrative that essentially asserted that:

  1. This stuff is really complex, Man. Lotta ins, lotta outs, lotta what-have-yous, Maude.
  2. Michael Lewis doesn’t know what he’s talking about, and he made shit up for the sake of a better narrative for his book.
  3. Anyway, the SEC is totally on the case in regards to any potential fraud in HFT trading.

Okay, up to this point, it’s just typical corporate weaseldom. Dude makes a boatload of dough for lying to himself and the public, and that’s that. This is not a moral hazard unique to the officers of BATS, that’s for sure. But here’s where it gets much more interesting…

After that third non-answer, I ask CFO Schell a follow-up question: “So you’re saying the SEC now has a full audit trail capability, even into trades that are conducted on dark pools?” The moment I finished the question, I saw our PR handler, who had greeted us and conducted the office tour, quickly rise from the back of the conference room and exit a side door into a main corridor. Hmmm.

Mr. Schell continued to try and use dry-erase markers on a whiteboard to show that BATS was shocked, shocked I tell you, that there could be any HFT front-running facilitated by his stock exchange. A few minutes later, the PR staffer returned to the room and announced that our time was up, and that unfortunately, CEO Ratterman had been called away to an urgent meeting and couldn’t meet with us after all. They then shuffled us out a side door, collected our visitor badges, and sent us on our way.

I want to be clear that I have no proof that Ratterman decided to bag out on our meeting because he didn’t want to answer any non-softball questions. However, the circumstances were interesting, to say the least. Couple our abrupt itinierary change with the fact that I took this photo of Ratterman’s office door during our tour, and draw your own conclusions:

Image

I know I did.

Note: For those interested in learning more about the material detailed in Flash Boys, and delving into the sordid underbelly of the financial world, I suggest the quasi-anonymous website www.zerohedge.com
Additional Note: For a good review of Flash Boys and some additional analysis, see my fellow blogger Thoughts of a Raving Geek at: https://wordpress.com/read/post/id/20156723/303/

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