money

may 16th

Robert Scheer's Columns
Obama Can’t Knock the Hustle
Posted on May 17, 2012
AP/Mark Lennihan

By Robert Scheer

How did we end up with such smart scoundrels? Even after it was known that Jamie Dimon’s bank blew more than $2 billion on the same suspect derivatives trading that has bankrupted the world’s economy, Barack Obama still had praise for the intellect of his political backer and the integrity of the bank he heads: “JPMorgan is one of the best-managed banks there is,” the president told the hosts of ABC’s “The View” in an interview televised Tuesday, adding, “Jamie Dimon, the head of it, is one of the smartest bankers we got. And they still lost $2 billion and counting.”

A lesser bank would have gone under and needed to be bailed out, Obama argued: “That’s why Wall Street reform is so important.” But even when fully implemented, Obama’s tepid reforms would not have stopped this scam and will not stop the others that are sure to follow. Being one of the smartest bankers means you are among those who best know how to skirt the law or, if that cannot be done, how to successfully lobby to gut it.

Dimon understands and performs this drill well, for he was in cahoots with his mentor, Sandy Weill, in engineering a series of mergers and acquisitions that would have violated the Glass-Steagall law, which for decades had prohibited commingling investment and commercial banking. The two business executives were able to get Congress and President Bill Clinton to reverse Glass-Steagall, a change that made legal the creation of Citigroup, the too-big-to-fail bank that eventually was saved from bankruptcy only through an immense taxpayer bailout.

The best and the brightest in this case are the bane of the nation because their genius lies in outwitting all efforts to hold them accountable. Dimon, the most recent in a parade of now-disgraced Wall Street golden boys, was nonetheless just awarded $24 million in compensation for 2011 by JPMorgan. Like his mentor Weill, who ran Citigroup into derivative trading hell, Dimon will no doubt suffer little legal unpleasantness or social ostracism stemming from his dodgy behavior. Weill will soon be inducted into the American Academy of Arts & Sciences as an outstanding business leader and philanthropist.

The fact that Dimon first rose to banking prominence as he worked alongside Weill to reverse Glass-Steagall did nothing to tarnish his reputation in Obama’s eyes. Although Dimon was instrumental in establishing Citigroup, he had a falling out with Weill and left the bank before the great crash. In his subsequent reincarnation at JPMorgan, now the country’s biggest financial conglomerate, Dimon was a major supporter of Democrats and had more access to the president than any other Wall Street leader.

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Dimon was not shy about turning to Obama, whom he had backed with campaign contributions, to complain about the Dodd-Frank regulations. With the JPMorgan CEO exercising his easy access to the president and his Treasury secretary, Tim Geithner, the new regulations concerning bank derivatives trading were rendered meaningless. What did Obama think would happen when he appointed Dimon’s chief Washington lobbyist, William Daley, who served as presidential chief of staff through 2011, when the Dodd-Frank regulations were being promulgated?

As an Associated Press investigative report documented, Dimon led the Wall Street pack in the number of personal meetings and telephone calls with Secretary Geithner while the Obama administration was calibrating its response to the banking meltdown. Dimon has been a Class A director of the New York Fed since 2007, when Geithner was president of that institution, and the two worked closely then on details of JPMorgan’s takeover of Bear Stearns with a $55 billion Fed loan. That’s in addition to the $25 billion in TARP funds JPMorgan received.

Dimon’s close ties to Obama, whom he knew well when both were based in Chicago, were at moments tested by Obama’s feints into populism, but fellow Chicagoans Daley and Rahm Emanuel, who preceded Daley as chief of staff, made it clear that disagreements between the White House and Dimon were merely rhetorical. How much more influence could Dimon have wanted than having his former lobbyist controlling the president’s schedule?

It was a charade: Dimon pretended to welcome some banking regulation and Obama responded with the weakest of reforms.

Crunch time came this past February when JPMorgan executives, including Ina Drew, the recently resigned head of the bank’s unit that was behind the billions in losses, met with Federal Reserve officials to secure guarantees that the portfolio trading that later got the company into trouble was in fact legal. That so-called portfolio hedging, which Sen. Carl Levin, D-Mich., said “is a license to do pretty much anything” and violates the intent of the law, has now in fact been accepted by both the Treasury Department and the Fed as legal. As a result, there is a regulatory loophole that Levin called “big enough ... that a Mack truck could drive right through it.” Evidently one did.

Accidentally Released - and Incredibly Embarrassing
Documents Show How Goldman et al Engaged in 'Naked Short Selling'

By Matt Taibbi

May 16, 2012 "Rolling Stone" - It doesn’t happen often, but sometimes God smiles on us. Last week, he smiled on investigative reporters everywhere, when the lawyers for Goldman, Sachs slipped on one whopper of a legal banana peel, inadvertently delivering some of the bank’s darker secrets into the hands of the public.

The lawyers for Goldman and Bank of America/Merrill Lynch have been involved in a legal battle for some time – primarily with the retail giant Overstock.com, but also with Rolling Stone, the Economist, Bloomberg, and the New York Times. The banks have been fighting us to keep sealed certain documents that surfaced in the discovery process of an ultimately unsuccessful lawsuit filed by Overstock against the banks.

Last week, in response to an Overstock.com motion to unseal certain documents, the banks’ lawyers, apparently accidentally, filed an unredacted version of Overstock’s motion as an exhibit in their declaration of opposition to that motion. In doing so, they inadvertently entered into the public record a sort of greatest-hits selection of the very material they’ve been fighting for years to keep sealed.

I contacted Morgan Lewis, the firm that represents Goldman in this matter, earlier today, but they haven’t commented as of yet. I wonder if the poor lawyer who FUBARred this thing has already had his organs harvested; his panic is almost palpable in the air. It is both terrible and hilarious to contemplate. The bank has spent a fortune in legal fees trying to keep this material out of the public eye, and here one of their own lawyers goes and dumps it out on the street.

The lawsuit between Overstock and the banks concerned a phenomenon called naked short-selling, a kind of high-finance counterfeiting that, especially prior to the introduction of new regulations in 2008, short-sellers could use to artificially depress the value of the stocks they’ve bet against. The subject of naked short-selling is a) highly technical, and b) very controversial on Wall Street, with many pundits in the financial press for years treating the phenomenon as the stuff of myths and conspiracy theories.

Now, however, through the magic of this unredacted document, the public will be able to see for itself what the banks’ attitudes are not just toward the “mythical” practice of naked short selling (hint: they volubly confess to the activity, in writing), but toward regulations and laws in general.

“Fuck the compliance area – procedures, schmecedures,” chirps Peter Melz, former president of Merrill Lynch Professional Clearing Corp. (a.k.a. Merrill Pro), when a subordinate worries about the company failing to comply with the rules governing short sales.

We also find out here how Wall Street professionals manipulated public opinion by buying off and/or intimidating experts in their respective fields. In one email made public in this document, a lobbyist for SIFMA, the Securities Industry and Financial Markets Association, tells a Goldman executive how to engage an expert who otherwise would go work for “our more powerful enemies,” i.e. would work with Overstock on the company’s lawsuit.

“He should be someone we can work with, especially if he sees that cooperation results in resources, both data and funding,” the lobbyist writes, “while resistance results in isolation.”

There are even more troubling passages, some of which should raise a few eyebrows, in light of former Goldman executive Greg Smith's recent public resignation, in which he complained that the firm routinely screwed its own clients and denigrated them (by calling them "Muppets," among other things).

Here, the plaintiff’s motion refers to an “exhibit 96,” which refers to “an email from [Goldman executive] John Masterson that sends nonpublic data concerning customer short positions in Overstock and four other hard-to-borrow stocks to Maverick Capital, a large hedge fund that sells stocks short.”

Was Goldman really disclosing “nonpublic data concerning customer short positions” to its big hedge fund clients? That would be something its smaller, “Muppet” customers would probably want to hear about.

When I contacted Goldman and asked if it was true that Masterson had shared nonpublic customer information with a big hedge fund client, their spokesperson Michael Duvally offered this explanation:

Among other services it provides, Securities Lending at Goldman provides market color information to clients regarding various activity in the securities lending marketplace on a security specific or sector specific basis. In accordance with the group's guidelines concerning the provision of market color, Mr. Masterson provided a client with certain aggregate information regarding short balances in certain securities. The information did not contain reference to any particular clients' short positions.

You can draw your own conclusions from that answer, but it's safe to say we'd like to hear more about these practices.

Anyway, the document is full of other interesting disclosures. Among the more compelling is the specter of executives from numerous companies admitting openly to engaging in naked short selling, a practice that, again, was often dismissed as mythical or unimportant.

A quick primer on what naked short selling is. First of all, short selling, which is a completely legal and often beneficial activity, is when an investor bets that the value of a stock will decline. You do this by first borrowing and then selling the stock at its current price, then returning the stock to your original lender after the price has gone down. You then earn a profit on the difference between the original price and the new, lower price.

What matters here is the technical issue of how you borrow the stock. Typically, if you’re a hedge fund and you want to short a company, you go to some big-shot investment bank like Goldman or Morgan Stanley and place the order. They then go out into the world, find the shares of the stock you want to short, borrow them for you, then physically settle the trade later.

But sometimes it’s not easy to find those shares to borrow. Sometimes the shares are controlled by investors who might have no interest in lending them out. Sometimes there’s such scarcity of borrowable shares that banks/brokers like Goldman have to pay a fee just to borrow the stock.

These hard-to-borrow stocks, stocks that cost money to borrow, are called negative rebate stocks. In some cases, these negative rebate stocks cost so much just to borrow that a short-seller would need to see a real price drop of 35 percent in the stock just to break even. So how do you short a stock when you can’t find shares to borrow? Well, one solution is, you don’t even bother to borrow them. And then, when the trade is done, you don’t bother to deliver them. You just do the trade anyway without physically locating the stock.

Thus in this document we have another former Merrill Pro president, Thomas Tranfaglia, saying in a 2005 email: “We are NOT borrowing negatives… I have made that clear from the beginning. Why would we want to borrow them? We want to fail them.”

Trafaglia, in other words, didn’t want to bother paying the high cost of borrowing “negative rebate” stocks. Instead, he preferred to just sell stock he didn’t actually possess. That is what is meant by, “We want to fail them.” Trafaglia was talking about creating “fails” or “failed trades,” which is what happens when you don’t actually locate and borrow the stock within the time the law allows for trades to be settled.

If this sounds complicated, just focus on this: naked short selling, in essence, is selling stock you do not have. If you don’t have to actually locate and borrow stock before you short it, you’re creating an artificial supply of stock shares.

In this case, that resulted in absurdities like the following disclosure in this document, in which a Goldman executive admits in a 2006 email that just a little bit too much trading in Overstock was going on: “Two months ago 107% of the floating was short!”

In other words, 107% of all Overstock shares available for trade were short – a physical impossibility, unless someone was somehow creating artificial supply in the stock.

Goldman clearly knew there was a discrepancy between what it was telling regulators, and what it was actually doing. “We have to be careful not to link locates to fails [because] we have told the regulators we can’t,” one executive is quoted as saying, in the document.

One of the companies Goldman used to facilitate these trades was called SBA Trading, whose chief, Scott Arenstein, was fined $3.6 million in 2007 by the former American Stock Exchange for naked short selling.

The process of how banks circumvented federal clearing regulations is highly technical and incredibly difficult to follow. These companies were using obscure loopholes in regulations that allowed them to short companies by trading in shadows, or echoes, of real shares in their stock. They manipulated rules to avoid having to disclose these “failed” trades to regulators.

The import of this is that it made it cheaper and easier to bet down the value of a stock, while simultaneously devaluing the same stock by adding fake supply. This makes it easier to make money by destroying value, and is another example of how the over-financialization of the economy makes real, job-creating growth more difficult.

In any case, this document all by itself shows numerous executives from companies like Goldman Sachs Execution and Clearing (GSEC) and Merrill Pro talking about a conscious strategy of “failing” trades – in other words, not bothering to locate, borrow, and deliver stock within the time alotted for legal settlement. For instance, in one email, GSEC tells a client, Wolverine Trading, “We will let you fail.”

More damning is an email from a Goldman, Sachs hedge fund client, who remarked that when wanting to “short an impossible name and fully expecting not to receive it” he would then be “shocked to learn that [Goldman’s representative] could get it for us.”

Meaning: when an experienced hedge funder wanted to trade a very hard-to-find stock, he was continually surprised to find that Goldman, magically, could locate the stock. Obviously, it is not hard to locate a stock if you’re just saying you located it, without really doing it.

As a hilarious side-note: when I contacted Goldman about this story, they couldn't resist using their usual P.R. playbook. In this case, Goldman hastened to point out that Overstock lost this lawsuit (it was dismissed because of a jurisdictional issue), and then had this to say about Overstock:

Overstock pursued the lawsuit as part of its longstanding self-described "Jihad" designed to distract attention from its own failure to meet its projected growth and profitability goals and the resulting sharp drop in its stock price during the 2005-2006 period.


Good old Goldman -- they can't answer any criticism without describing their critics as losers, conspiracy theorists, or, most frequently, both. Incidentally, Overstock rebounded from the 2005-2006 short attack to become a profitable company again, during the same period when Goldman was needing hundreds of billions of dollars in emergency Fed lending and federal bailouts to stave off extinction.

Anyway, this galactic screwup by usually-slick banker lawyers gives us a rare peek into the internal mindset of these companies, and their attitude toward regulations, the markets, even their own clients. The fact that they wanted to keep all of this information sealed is not surprising, since it’s incredibly embarrassing stuff, if you understand the context.

More to come: until then, here’s the motion, and pay particular attention to pages 14-19.

UPDATE: Well, I guess I shouldn't feel too badly for the lawyer who stepped on this land mine. For Morgan Lewis counsel Joe Floren, karma, it seems, really is a bitch.
Copyright ©2012 Rolling Stone; Jann S. Wenner, editor and publisher
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Can A Bank act like this and not be prosecuted?


Wells Fargo Has Blood on Its Hands:
Desperate Man Commits Suicide After Shocking Foreclosure Mistreatment

By Dave Johnson

May 16, 2012 "AlterNet" --- Norman and Oriane Rousseau were one more couple pushed by a huge, greedy bank to the brink of homelessness. On Sunday, desperate and with nowhere to go, Norman Rousseau shot himself.

This is the story of what happens when an average couple is up against a giant, wealthy, powerful bank. Unfortunately the result is what the result always is when people are on their own against the wealthy and powerful: the bank ends up with all of their money, takes their house to sell and throws them out onto the street. In this case the bank is Wells Fargo.

The quick version of this terrible story is that Norman and Oriane Rousseau of Newbury Park, California were scammed into a predatory mortgage. But they made their payments anyway, always paying with a cashier’s check in person at the same branch. Then one day the bank misapplied their payment and said they still owed the money. This started a long, nasty process that led to the bank evicting the Rousseaus from their home.

Here’s the shocker: right at the start the Rousseaus came up with proof that the bank had received the payment and had cashed the check. But the bank continued to claim it had missed the payment, gave the Rousseaus the runaround, started applying fees, and used it as an excuse to foreclose on the house anyway.

The Rousseaus fought back, the bank dragged it out for so long and pulled so many tricks, getting its way every step of the process, until this last Sunday Norman Rousseau finally gave up and shot himself in despair – two days before the scheduled eviction, Tuesday, May 15. (The Rousseau’s lawyer just said he was able to win a 2-week delay.)



It is a tragic story, but when you dig into the details it becomes much worse.

See for yourself. The court case filed by the Rousseaus puts on the record the facts as they state them. The complaint reads as one more story like so many others that we have been hearing about the abuses by banks and banksters and the tricks they pulled on people. Never mind the big “National Mortgage Settlement” – this story shows that the abuses are still going on, with the same tragic consequences.

The following describes the facts in the lawsuit filed in Norman Rousseau and Oriane Rousseau vs. Wells Fargo Bank in the Superior Court of California, County of Ventura.

In March 2000, Norman and Oriane Rousseau put 30 percent down to buy a house at 580 Wilshire Place, Newbury Park, CA. In the following years they were solicited to refinance their loan. In October 2007 they met with the loan officer and “stated that they were only interested in obtaining a conventional 30-year, fixed-rate loan, and explained their desire to have consistent payments over the life of the loan.”

They were “assured … that they could significantly reduce their monthly payments, by more than $600 per month, with a lower interest refinance loan.” The bank assured them that the Payment Option ARM was “the new industry standard” that had “historically low rates that were continuing to decrease” and in “the worst case scenario [they were] assured that historical data for the index indicated that changes in interest rate were slight, and if an increase should occur it would have a negligible effect on their monthly payments of no more than a few dollars.”

They should “expect to refinance within the next two years to take advantage of even more favorable interest rates and as the steadily rising housing values increased the amount their equity in the property.”

There were lots of assurances, smiles, don’t worry, we’re taking care of you, etc.

In May 2009 the bank claimed the couple had missed their April payment. They proved they had made a payment in person at the bank, using a cashier’s check and that the check had been cashed by the bank. The bank then claimed they had ordered a stop payment on the check, even though a cashier’s check payment cannot be stopped.

The runaround began. The bank began harassing them for payment, sometimes as many as six-eight calls per day, sometimes even late at night. On August 3, 2009 the bank claimed the Rousseaus hadn’t paid June or July’s payments either, demanding $3,406.50. But then on August 8 the bank assured them they were current on payments. Then the bank again claimed it had not been paid and that the bank had been trying to contact them without success, and that they now owed $3,478,25.

The Rousseaus hired a lawyer. From the lawyer the Rousseaus learned that the loan they received was not the loan they were promised, including, “the 7.2% interest rate for the … loan was actually higher than the 2006 loan and greater than the 6.8% quoted,” had enormous fees, and the bank had increased the income the Rousseau had stated, from $76,000 to $136,800.

In other words, the lender had scammed them to get those fees, which was a widespread practice at the time.

This continues, with the bank scamming, lying, obfuscating, ignoring, contradicting, even producing signatures it claimed were the Rousseau’s but were not, every step of the way. And, of course, adding late fees to the amount it claimed was due.

In September the bank stopped accepting payments at the branch, saying checks had to be mailed. About the same time the Rousseaus applied for a loan modification. They were told they were accepted for review in the loan modification program, were told the “pre-foreclosure” notices were “routine” and not to worry about them. Their lawyers were handling getting documents to the bank, the bank kept claiming it never received them, etc.

On and on this went, with the bank telling them they were in the loan modification program while demanding money then refusing to accept money and demanding documents while saying it had received them, and all the while proceeding with foreclosure notices. Then they were told they were denied their loan modification, went through a process to reinstate the loan, back and forth, late fees, loan fees, unspecified additional fees, more fees, then some fees, then some non-payment fees, and then given ONE HOUR to send payments to TEXAS and it goes on and on.

Read the court case the Rousseaus filed. It’s all there, and is even worse than this summary.

This is a story of what happens when, as Senator Dick Durbin said of the Senate during the effort to pass legislation to get the banks under control, “Frankly they own the place.”

This last Sunday the bankers claimed one more victim. Norman Rousseau shot himself at 10 in the morning. Oriane Rousseau doesn’t even have the money to bury her husband, she is looking to the VA for help. If you want to help, please contact their attorney, Chris Gardas: chrisgardas@comcast.net

Martin Mandelman broke this story yesterday at Mandelmann Matters: Husband’s Suicide Yesterday, Wells Fargo to Evict Wife Tomorrow Anyway.

Dave Johnson is a fellow at Campaign for America's Future and a senior fellow at Renew California.
© 2012 Independent Media Institute. All rights reserved.*
MAY 2012
"The terrible, cold, cruel part is Wall Street. Rivers of gold flow there from all over the earth, and death comes with it. There, as nowhere else, you feel a total absence of the spirit: herds of men who cannot count past three, herds more who cannot get past six, scorn for pure science and demoniacal respect for the present. And the terrible thing is that the crowd that fills the street believes that the world will always be the same and that it is their duty to keep that huge machine running, day and night, forever." - Federico Garcia Lorca - Spanish Poet and Playwright

"Formula For Fraud" How To Become A Billionaire

William K. Black from the first Italian economic Summit on Modern Money Theory in Rimini, Italy.

How to become a billionaire - the four necessary ingredients in the recipe for fraud; the three sure consequences of banking control fraud; gutting of the underwriting process; Gresham's Law; The Business Roundtable; hyperinflation of a bubble.

Guns and Butter, Broadcast April 4, 2012



Transcript

“And here’s the key question: How many of you are bankers? Not many, right? How much brains does it take to make a bad loan? I think we could all do that. So, all the mediocre bankers have no way to make money with honest competition. But they have a sure thing, if they’re willing to follow the fraud recipe.” —William K. Black

“I’m Bonnie Faulkner. Today on Guns and Butter: William K. Black. Today’s show: 'Formula For Fraud.' William Black is Associate Professor of Law and Economics at the University of Missouri, Kansas City. He is a lawyer and former bank regulator and author of The Best Way to Rob a Bank is to Own One: How Corporate Executives and Politicians Looted the S&L Industry.

“According to William Black, the current crisis is 70 times larger than the collapse of the savings and loan industry in the late 1980s. Today’s programme includes two of Bill Black’s presentations on Saturday, February 25th in Rimini, Italy at the first Italian grassroots economic Summit on Modern Money Theory produced by Italian Journalist Paolo Barnard, which featured speakers Stephanie Kelton, William Black, Marshall Auerback, Michael Hudson, and Alain Parguez.

“In today’s show, Black deconstructs the elements that constitute the recipe for fraud.”

William Black (c. 2:05): “It’s difficult to follow such a raging optimist. [Applause] But I can assure you, it’s actually far worse than they say. First, there are no 'technocrats,' especially the ‘genius’ technocrats. I suggest a new rule of thumb for judging a 'genius technocrat.' They have to be right at least two out of ten times. And there’s not a single economist in Europe, who calls himself a technocrat, that could do the equivalent of making two penalty kicks out of ten. So, I’m going to pick up on some of the things that Michael [Hudson] has talked about. He quoted Balzac’s famous phrase that behind every fortune lies a great scandal. And I’m going to explain how that works. So, you will now learn how to steal €10 billion euros. [Applause] The purpose of this is not so that you will steal €10 billion euros. The purpose is so that you can be an intelligent lion because they feed on sheep.

(c. 3:40) “We’ve been asked to do our talks in four parts. So, unlike Gaul, my speech is divided in four parts. This talk will be about why we suffer recurrent, intensifying, financial crises. Then, I’ll explain how theoclassical economic dogma produces these disasters. The third part will be to explain why our response to the crisis has made it worse. And I actually will end on an optimistic note. The fourth part is how we have succeeded in some places at some times and why you can do the same.

(c. 4:29) “Part one sounds like one question: Why do we have recurrent, intensifying, financial crises? But it’s really two questions. The first one asks: What is the cause of these crises? The second one says: Well, wait a minute. We keep on suffering crises. Why don’t we learn the right lessons from these crises? So, part one will focus on what caused the crises.

(c. 5:05) “Part two will focus on why ideology prevents us from learning the right lessons.

“Santayana’s famous phrase, of course, is that those that forget the mistakes of the past are condemned to repeat them. But, even if we remember the mistakes we’ve made, the new policy we pick could be another mistake. So, part three discusses that, in part.

“But part four says the real tragedy is when you forget the successes of the past, when you have something that you know works and that you refuse to use. Because, as Michael [Hudson] said, there’s not an economics textbook in the world that warns you that elite CEOs often become wealthy through fraud. And there is a primitive, tribal, taboo in economics in English against using the five-letter eff-word—fraud. When I go and talk to groups of economists who are traditional, I start out the meeting by asking them each to say out loud the word fraud. You can’t believe how difficult it is for them, even, to utter the word.

(c. 6:42) “So, as I said, the lessons of success, it’s a real tragedy to forget them. And I’m going to quote from George Akerlof and Paul Romer’s famous article, or, at least, an article that should be famous where the title says it all: 'Looting: The Economic Underworld of Bankruptcy for Profit.' So, the bank fails or, in the modern era, is 'bailed' out, but the CEO walks away wealthy. And this is what Akerlof and Romer wrote about 20 years ago:

“‘Neither the public, nor economists foresaw that savings and loan deregulation was bound to produce looting, nor, unaware of the concept, could they have known how serious it would be. Thus, the regulators in the field who understood what was happening from the beginning found lukewarm support, at best, for their cause. Now, we know better. If we learn from experience, history need not repeat itself.'

(c. 8:22) “George Akerlof was awarded the Nobel Prize in Economics in 2001. So, you might think economists would pay attention. You might think, since this article was written nearly 20 years ago, that the textbooks would mention fraud and looting. They don’t just ignore everyone here. They ignore Nobel Prize winners in Economics.

“So, what, again, was this lesson? It was the regulators in the field, the little people, not the fancy people, who understood from the beginning that deregulation would lead to massive looting. And it was the economists that ignored them. And after we had proven that it was fraud, after we had sent over a thousand elite bankers and their cronies to prison, after a Nobel Prize winner warned about it, after all those things, they ignored it and produced crisis after crisis, including the one we experience now.

(c. 9:59) “So, what did we know out of that savings and loan crisis, that was widely described at the time as the worst financial scandal in U.S. history? And we have a history rich in scandal. Here is what the national commission that investigated the causes of the crisis reported:

"'The typical large failure [grew] at an extremely rapid rate, achieving high concentrations of assets in risky ventures... [E]very accounting trick available was used... Evidence of fraud was invariably present, as was the ability of the operators to 'milk' the organisation.'

(c. 11:04) "That means to loot the organisation. But, speaking of milk, [Applause] the frauds I’m describing are in no way limited to the Unites States; they exist in every country. And they are common enough to explain; and they are old enough to explain what Balzac was saying because many of the wealthy become rich through precisely the scandals, the fraud, I will describe.

“In criminology, we call them financial super predators when we’re being lyrical. When we’re writing journals, we call them ‘control frauds,’ which is boring. Control fraud occurs when the person who controls a seemingly legitimate entity, like Parmalat, uses it as a weapon to defraud. And they can often use this weapon with impunity. In finance, accounting is the weapon of choice. And these accounting frauds cause greater losses than all other property crimes combined, yet economics, again, never talks about it. Worse, when many of these frauds occur in the same area, they hyperinflate financial bubbles, which is what causes financial crises and mass unemployment. It makes the CEOs wealthy, produces Balzac scandals, and destroys democracy.

(c. 13:10) “In criminology, we talk about criminogenic environments, long words, simple concept. When the incentives are extremely perverse, you will get widespread fraud. So, what makes for perverse incentives? The ability to steal a lot of money and not go to prison and not having to live in disgrace. In practice that means, in English, the three Ds: deregulation, desupervision, and de facto decriminalisation. Deregulation, you get rid of the rules. Desupervision, any rules that remain, you don’t enforce. Decriminalisation, even if you sometimes sue them and get a fine, you don’t put them in prison. So, that’s the first area—deregulation. The second area is executive compensation.

(c. 14:25) “And what is ideal for accounting fraud? Really high pay based on short-term reported income with no way to claw it back, even when it proves to be a lie. Those are the most important, but it’s also good, if your assets don’t have a readily verifiable market-value ‘cos then it’s easy to inflate the asset prices and it’s easy to hide the real losses. And, if you want a true epidemic of fraud, if entry into the industry is very easy then you’ll get much more fraud.”

Bonnie Faulkner (c. 15:15): “You’re listening to lawyer, academic, author, and former bank regulator William K. Black. Today’s show: 'Formula for Fraud.' I’m Bonnie Faulkner. This is Guns and Butter.”

William Black: “So, this is what you were waiting for, at least from me. This is the recipe, only four ingredients, that bankers in many parts of the world use to become billionaires. And, again, it’s one that Akerlof and Romer agreed with. So, first ingredient: grow massively. Two: by making really, really crappy loans, but at a higher interest rate. Third ingredient: extreme leverage—that just means a lot of corporate debt. Fourth ingredient: set aside virtually no loss reserves for the massive losses that will be coming. By the way, in Europe, this last ingredient is mandated by international accounting rules, which are incredibly fraud-friendly. And everybody knows that, in accounting; and nobody has changed it. If you do these four things, you are mathematically guaranteed to report record short-term income. This is why Akerlof and Romer referred to it as a sure thing—it’s guaranteed.

(c. 17:11) “There are actually three sure things. The bank will report record profits. The profits, of course, are fictional. The CEO will promptly become wealthy and, down the road, the bank will suffer catastrophic losses. Again, if many banks do this, you will hyperinflate a bubble. This recipe helps explain why bankers hate markets, why bankers hate capitalism, why they hate anything like an effective market.

“So here’s a thought exercise: What if you were a CEO of a bank and you wanted to grow exceptionally rapidly? The first ingredient to the fraud recipe, that means 50% a year. And that’s realistic; that’s what the banks in Iceland, that’s what many of the banks in Europe—continental Europe—and the U.S. also did. How would you do that if you were honest? You’re in a market that’s competitive. The only way to grow that rapidly is to charge far less money, a lower interest rate, for your loans. But if they’re a real market what would your competitors do? They would match your price reduction. You wouldn’t end up making anymore loans; and all the banks would be loaning at a lower interest rate. So, here’s the question? Is that a good way to make money as a bank? It’s a terrible thing for a bank, right? So, all the bankers would lose. And that’s why they hate markets. And that’s why banks are the biggest proponents of crony capitalism and the leaders worldwide in crony capitalism.

(c. 19:26) “And that leads us to a discussion of why bad loans are so perfect for bank fraud; you can charge a much higher rate to people who can’t get loans because they can’t repay the loans. And there are millions, tens of millions, of such people. So, you can grow very rapidly. You can charge a higher interest rate. If your competitors do the same thing, it’s actually ‘good’ for you because it hyperinflates the bubble. And the bad loans, you just refinance them and you hide the losses for many more years.

(c. 20:22) “So, the CEO takes no risk; all of this is a sure thing. And here’s the key question: How many of you are bankers? Not many, right? How much brains does it take to make a bad loan? I think we could all do that. So, all the mediocre bankers have no way to make money with honest competition. But they have a sure thing, if they’re willing to follow the fraud recipe. I’m now gonna quote from the person, the economist [James Pierce, NCFIRRE's Executive Director], who led the national investigation of the savings and loan crisis. And he called this dynamic I’ve just explained, 'the ultimate perverse incentive.' So, this is what he said:

(c. 21:28) "‘Accounting abuses also provided the ultimate perverse incentive: it paid to seek out bad loans because only those who had no intention of repaying would be willing to offer the high loan fees and interest required for the best looting. It was rational for operators’—that’s CEOs—‘to drive their banks ever deeper into insolvency, as they looted them.’

(c. 22:12) “That is how crazy a world that theoclassical economics has built, where the best way, the surest way, to become wealthy, as a bank CEO, is to make the worst possible loans. And to make so many bad loans, they have to gut the underwriting process. Underwriting is what an honest bank does to make sure that it’s going to get repaid. But, if you want to make bad loans, you have to get rid of your effective underwriting. So, this is the key, if you get rid of underwriting.

(c. 23:01) “We already established you’re not bankers. So, imagine all of you run Competent Honest Bank and you do underwriting. And you can tell can tell high-risk and low-risk borrowers. Low risk borrowers you charge 10%. High-risk borrowers you charge 20%. I run Bill’s Incompetent Bank, I can’t tell risk. So, I charge everybody 15%. Which borrowers come to me? Only the absolute worst borrowers. No good borrower would come because they could borrow at your bank at 10%. So, this is not like a usual risk. In economics, we call this adverse selection. And it means that a bank that makes loans this way must lose vast amounts of money. No honest banker would operate this way. And the banks that engage in these frauds also create criminogenic environments themselves to recruit fraud allies. For example, the people that value homes, if they won’t inflate the value, the dishonest banks won’t use them. Do they need to corrupt every person that values homes? No. 5% of the profession would be fine. They just send all their business to the corrupt—we call them—appraisers in America. And this is called a Gresham’s Dynamic; and it means that cheaters prosper and bad ethics drives good ethics out of the marketplace.

(c. 25:20) “Well, what about compensation? In [the U.S.A.], the largest corporations, the largest 100, created a group to lobby called the Business Roundtable. And you remember our Enron-era frauds, early 2000s? Well, they got embarrassed. And, so, they appointed a task force to look at the frauds. And they named a particular CEO as head of their task force; and he was asked by Business Week, why do we have all these frauds? This is the answer he gave:

“‘Don’t just say: 'If you hit this revenue number, your bonus is going to be this.' It sets up an incentive that’s overwhelming. You wave enough money in front of people; and good people will do bad things.’

(c. 26:28) “And that was Franklin Raines, the head of Fannie Mae, which is now insolvent by about $500 billion dollars. How did Frank Raines know about this perverse incentive? Because he used it at Fannie Mae to produce the frauds that made him wealthy.

“How about Ireland? This is a report by a Scandinavian banker hired to do an investigation, not a real investigation, of course. He reported:

“‘Bonus targets that were intended to be demanding through the pursuit of sound policies and prudent spread of risk were easily achieved through volume lending to the property sector.’

(c. 27:25) “Now, that requires a translation, not because it’s written in English, but because it’s written to be not understood. So, what is he really saying? The bank CEO sets a target for income that is huge—three times the current income. How can you triple income safely? Wow, if somebody could really do that safely, we’d be happy to pay them a very big bonus, right? But what does he say?

“You don’t have to do it safely. And it isn’t hard. You just follow the fraud recipe and it’s a sure thing. It’s easily achieved.

“What’s wrong with his sentence, though?

“He says the targets were intended to be difficult, demanding. And they were intended to be met through prudent lending.

(c. 28:34) “Seriously, you think that? The CEO is deciding how much money he is going to make. Do you think he intended a demanding target or a target that was easily achieved and would make him wealthy?

“So, I will end on this. We need a coast guard for our banks. We can no longer allow CEOs to desert their posts after running their banks aground and causing such great destruction. The cruise ship's captain’s career is over. But the elite bank CEOs that destroyed the global economy remain wealthy, powerful, and famous because they looted. They were ‘bailed’ out. They did not leave in a lifeboat in the dark of night. They left in their yachts, yachts that the governments paid for. And no official anywhere in the world has demanded of those bank CEOs who deserted their vessels [...] [Applause] Grazie.”

Bonnie Faulkner (c.30:30): “You’re listening to lawyer, academic, author, and former bank regulator William K. Black. Today’s show: ‘Formula for Fraud.’ I’m Bonnie Faulkner. This is Guns and Butter.”

William K. Black: “Someone called on the Black Plague? I’m here. [Laughter, Applause]

“In this part two, I’m going to talk about why we have recurrent, intensifying crises, why we don’t learn the right lessons from our past crises. And then we’re going to discover something that, of course, you’ve been hearing. The dominant economists are truly terrible at one thing. They are terrible at economics. But occasionally they go beyond economics and they are abysmal on ethics. And they are the leading opponents and dangers to democracy throughout the EU, in particular, but in America as well.

(c. 31:40) “Economists tell us they want to be judged on their predictive ability. We welcome their admission because their record in prediction is pitiful. But, of course, it is precisely the fact that they've been wrong about everything important for three decades that makes them unwilling to admit their error and evermore insistent on continuing their worst policy advice.

(c. 32:12) “As I said economics is particularly awful when it gets into the concept of morality. In my first talk, I read you a quotation from the economist who conducted the investigation of the savings and loan crisis. And he pointed out that it was ‘rational’ for looters to make bad loans. Well, here is the reaction of one economist, Greg Mankiw, to hearing the work of that national commission and of that Nobel Prize winner-to-be, George Akerlof. He listened to their story and he said—and this is not an off-hand comment; he was the official discussant; he had the paper a week in advance; he thought about these remarks—he said:

"‘[...] it would be irrational for savings and loans [CEOs] not to loot.’

“So, note that he goes from simply a statement about how you maximise fraud by making bad loans to the ethical proposition that it would be rational action, it must be the appropriate action, even though the rational action is to defraud.

(c. 33:40) “Now, there’s a very interesting book called Moral Markets that had the unfortunate timing to come out in 2008 because it is a triumphal book about capitalism and about how capitalism makes markets more moral. But even it contains this statement:

“‘Homo economicus is a sociopath. Homo economicus is what happens if people behave the way economists predict that they will behave.’

“And these scholars, who love capitalism, said: if you do that, you will create a nation of sociopaths.

“Greg Mankiw was not a random economist. [Then-]President Bush made him Chairman of the President’s Council of Economic Advisers, the most prominent economic position in [the U.S.A.] after he had said these things.

(c. 34:48) “The next two gentlemen are the leading law and economics scholars on corporate law. And I’m quoting from their treatise in 1991; so, an entire generation of U.S. lawyers have been taught this next phrase:

“‘A rule against fraud is not an essential or [...] an important ingredient of securities markets.’

“The key economist there—who is not really an economist, he’s a lawyer—is Daniel Fischel. He worked for three of the worst control frauds, including the absolute worst savings and loan 'control fraud,' praised them as the best firms in [the U.S.A.], and then wrote this two years later without ever admitting in his book that he had tried his theories in the real world and they had led him to praise the worst frauds. So, this is rank academic dishonesty on top of getting everything wrong. And what happened to Fischel after he got everything wrong? He was made Dean of the University of Chicago Law School, one of the most prominent academic positions in [the U.S.A.]

(c. 36:15) “Alan Greenspan also worked for the worst fraud in the savings and loan crisis. Charles Keating’s Lincoln Savings. And he personally recruited, as a lobbyist for this worst fraud, the five [bipartisan] U.S. Senators who would intervene with us to try and prevent us from taking enforcement action against the largest violation in the history of our agency because that violation was by Charles Keating and Lincoln Savings. And those five senators became known and ridiculed as the Keating Five. By the way, [Republican Senator] John McCain was one of those senators who met with us. [The other four were Democrats.]

“Alan Greenspan then wrote a letter saying we should allow Lincoln Savings to do these terrible investments because ‘they posed no foreseeable risk of loss to the federal insurance fund.’ Lincoln Savings proved to be the largest cost to the insurance fund. After he had gotten it as wrong, as it is possible to get something wrong, we made him Chairman of the Federal Reserve. So, here you have a record of we promote and honour, in economics, the people who get it spectacularly wrong, as long as they get it wrong for powerful banks that are frauds.

(c. 37:59) “So, what did they predict? This is the short list. Neoclassical economists predicted that because markets were efficient they were self-correcting, fraud was automatically excluded, and financial bubbles could not occur.

"They assured us that because of bankers’ interest in their reputations and auditors and appraisers, that they would never commit a fraud and never assist a fraud.

"They predicted that massive financial derivatives would stabilise the economic system.

"They told us, even when the bubble had reached proportions larger than any in the history of the world, that there was no housing bubble in the United States, that there was no housing bubble in Ireland, that there was no housing bubble in Japan, that there was no housing bubble in Spain.

"They told us that if we paid CEOs massive amounts of money based on short-term performance that was fictional, it would align the interests of the CEO with the shareholders and the public and be the best possible thing.

(c. 39:30) “Every one of these predictions proved utterly false. Actually, every single one of these predictions had been falsified before the economists ever said them; and they did not change.

"What did they do back in the day? They looked at Europe. This is Cato, named, of course, after a famous Roman—a very conservative anti-think tank in the United States. Cato, in 2007, as Iceland was collapsing in massive fraud, said these words:

“‘Iceland’s economic renaissance is an impressive story. Supply-side reforms’—that means tax cuts—‘along with policies, such as privatisation and deregulation, have yielded predictable results.’

"Remember, we’re making predictions.

"‘Incomes are rising, unemployment is almost non-existent, and the government is collecting more revenue from a larger tax base.’

"So, they cut taxes, but overall tax revenue grows because the country is growing at a massive rate. Why? Because the big three banks in Iceland are all accounting control frauds. They are growing at an average rate of 50% every year. And by the time they collapse in 2008, they are ten times the GDP of Iceland. And they suffer 60% losses on their assets. That was their prediction of proof-positive that deregulation, low taxes, privatisation produce economic booms.

(c. 41:36) “They said something very similar about Ireland in an article entitled 'It’s Not Luck':

"Ireland [...] boasts the fourth highest gross domestic product per capita in the world. In the mid-1980s, Ireland was a backwater with an average income level 30% below that of the European Union. Today, Irish incomes are 40% above the EU average.

"'Was this dramatic change the luck of the Irish? Not at all. It resulted from a series of hard-headed decisions that shifted Ireland from big government stagnation to free market growth.'

"And they wrote this in 2007, a year after the Irish bubble had popped and Ireland was going into freefall. And what are we being told now is the answer? Hard-headed decisions that shift the governments from big government stagnation to free market growth. They have learned absolutely nothing from their past failed ‘predictions.’ In fact, Trichet came to Ireland in 2004 and said Ireland should be the model for nations joining the European Union.”

Bonnie Faulkner (c. 43:20): “You’re listening to lawyer, academic, author, and former bank regulator William K. Black. Today’s show: ‘Formula for Fraud.’ I’m Bonnie Faulkner. This is Guns and Butter.”

William K. Black: “But we have seen this movie many times before in many countries. We had seen it in the savings and loan crisis. But then came the Enron-era crisis and WorldCom. And I’ll focus on just one aspect. Again, we had accounting control fraud that drove an immense crisis. But what people forget is that most of the world’s largest banks eagerly aided and abetted Enron’s frauds. They knew Enron was engaged in fraud; and they thought that was a good thing because they would get more deal flow, as we say, more volume. These frauds were documented extensively by investigations, hundreds of pages about it. Not a single one of the large conventional bankers were prosecuted. There was a prosecution about Merrill Lynch, which the courts obstructed. Indeed, the U.S. Supreme Court ruled that only the government could bring civil suits—against an enforcement action, of course—against banks that aided and abetted fraud. Think of that! You could have indisputable proof that the bank had aided Enron, knowingly done so, caused you billions in losses, and you could not sue the bank. That’s how bad the law has become in the United States.

(c. 45:26) "So, that left us with could the government sue? Well, the Federal Reserve, we now know from recent testimony in front of the national commission that investigated this current crisis, the leadership actively resisted bringing any action against the banks, even what we call a slap on the wrist. And it was only when the Securities and Exchange Commission took a slap on the wrist that the Federal Reserve was embarrassed into taking any action. We also know, from this extraordinary testimony by the long-time head of supervision at the Federal Reserve that he was deeply disturbed by the fact that most of the largest banks in the world had aided Enron’s fraud. So, he put together a comprehensive briefing for the leadership of the Federal Reserve. At that meeting, the senior officials of the Federal Reserve and the senior Economists of the Federal Reserve did not criticise Enron and they did not criticise the banks that aided Enron’s frauds. They were enraged at the Supervisor. How dare he criticise banks? And this was the era—and continues—in the United States to be the era of reinventing government, which is a neoclassical, neoliberal, be soft on bankers. And I witnessed, personally, when our Washington staff came at a training conference and instructed us that we were to refer to banks as our clients. We were the regulators. And we were, not only, supposed to refer to them as clients, we were supposed to treat them as clients. Being a quiet type, I stood up and began protesting; and they simply shouted us down. [Applause]”

(c. 47:59) “So, this was occurring in 2001, 2002, 2003, 2004. At that point, Italy enters the picture. And Italy enters the picture because of Parmalat. And it enters the picture because, again, you have a massive accounting control fraud where the CEO is looting Parmalat and taking the money out of Italy to tax havens where he can hide it in a wave of special complex corporate forms designed to hide the fraud. And what does the Federal Reserve say about all of this? Well, first they brag about their ‘enforcement’ action. Note that they won’t name the large institutions:

"'In these enforcement actions, certain large institutions were required to revise their risk management practices where examiners found failures by these institutions to identify those transactions that presented heightened legal and reputational risk, particularly, in cases where transactions were used to facilitate a customer’s accounting or tax objective that resulted in misrepresenting the company’s true financial condition to the public and regulators.'

(c. 49:42) “So, this is another passage that requires translation, not because it’s in English, but because it’s in gobbledygook. So, what are they really saying? First, they are bragging about an enforcement action that they tried very hard not to bring and which was utterly useless. Second, note what their concern is. Their concern is heightened legal and reputational risk. They’re worried that when the bank aids Enron or Parmalat’s frauds they’ll get caught and then their reputations will suffer. They’re not worried about Enron’s shareholders. They’re not worried about the 12,000 Enron employees who lose their jobs. They’re not worried about Parma’s economy. None of that matters. They don’t even discuss it. And they’re not worried about morality. Call me old school, but I thought, when I was a regulator, if the banks I was regulating were engaged in fraud, first, my job was to stop it. Second, my job was to remove the CEO from office. Third, my job was to help prosecute him and put him in prison. And, fourth, my job was to sue him, so that he walked away with not a lira or a euro or a dollar. But all of that is gone. [Applause]

(c. 51:25) “But you know this because you have probably seen a gem of a film. And you know, probably, what Citicorp called this special vehicle it created to facilitate the looting of Parmalat. Somehow, I think this means black hole; that’s what they called it. And this is so wonderful. Citicorp eventually said it regretted one thing, calling it bucanero. The only thing it was honest about is the only thing it regretted. What it did to Italy in Parma, not so much.

(c. 52:15) “So, what did people find in this crisis? This is the National Commission Report on our crisis:

"'We conclude widespread failures in financial regulation and supervision proved devastating to the stability of the nation’s financial markets. The sentries were not at their posts [...] due to the widely-accepted faith in the self-correcting nature of the markets and the ability of financial institutions to effectively police themselves.'

"It specifically blames Greenspan and his deregulatory ideology. That could have helped to avoid a catastrophe.

(c. 53:05) “But those are words. Here is an image. The person—yes, this man—he is 'Chainsaw Gilleran.' That translates very well into Italian, I see. He was the head of the agency I used to work for. He is standing next to the leading bank lobbyists in America and the guy who will be his successor. They are poised and posed over a pile of federal regulations. And, if that’s too subtle, they are tied up in red tape. And the message is: We will work with our clients, the banks, to destroy all regulation. And the reason we bring a chainsaw is to make clear that everything will be destroyed.

(c. 54:00) "Well, what about Europe? There was a conservative dissent to the conclusions I’ve just read. They claimed that deregulation could not have been a major cause of the crisis in [the U.S.A.] because the crisis also occurred in Europe. That’s all they said. They implicitly assumed that Europe must have been tough on bank regulation.

“I will conclude with these words from the report on the Irish Crisis. There were 'generic weaknesses in EU regulation and supervision.' So, the dissent has it exactly wrong. They’re right; it’s important to look at Europe and the same causal mechanism—deregulation, desupervision, and this absurd executive compensation—swept Europe and America. And the economists got what they wanted and predicted it would be wonderful. It produced a catastrophe. [Applause]"

Bonnie Faulkner (c. 55:30): “You’ve been listening to William K. Black. Today’s show has been ‘Formula for Fraud.’ William Black is Associate Professor of Law and Economics at the University of Missouri, Kansas City. He is a lawyer, academic, and former bank regulator and the author of The Best Way to Rob a Bank is to Own One: How Corporate Executives and Politicians Looted the S&L Industry.

“Please visit the University of Missouri, Kansas City New Economic Perspectives blog at www.NewEconomicPerspectives.org Visit the website for the first Italian Summit on Modern Money Theory at www.DemocraziaMMT.info

Insider trading 9/11 ... the facts laid bare

By Lars Schall

March 20, 2012 "Asia Times" - -Is there any truth in the allegations that informed circles made substantial profits in the financial markets in connection to the terror attacks of September 11, 2001, on the United States?

Arguably, the best place to start is by examining put options, which occurred around Tuesday, September 11, 2001, to an abnormal extent, and at the beginning via software that played a key role: the Prosecutor's Management Information System, abbreviated as PROMIS. [i]

PROMIS is a software program that seems to be fitted with almost "magical" abilities. Furthermore, it is the subject of a decades-long dispute between its inventor, Bill Hamilton, and various people/institutions associated with intelligence agencies, military and security consultancy firms. [1]

One of the "magical" capabilities of PROMIS, one has to assume, is that it is equipped with artificial intelligence and was apparently from the outset “able to simultaneously read and integrate any number of different computer programs or databases, regardless of the language in which the original programs had been written or the operating systems and platforms on which that database was then currently installed." [2]

And then it becomes really interesting:

What would you do if you possessed software that could think, understand every major language in the world, that provided peep-holes into everyone else’s computer "dressing rooms", that could insert data into computers without people’s knowledge, that could fill in blanks beyond human reasoning, and also predict what people do - before they did it? You would probably use it, wouldn't you? [3]

Granted, these capabilities sound hardly believable. In fact, the whole story of PROMIS, which Mike Ruppert develops in the course of his book Crossing the Rubicon in all its bizarre facets and turns, seems as if someone had developed a novel in the style of Philip K Dick and William Gibson. However, what Ruppert has collected about PROMIS is based on reputable sources as well as on results of personal investigations, which await a jury to take a first critical look at.

This seems all the more urgent if you add to the PROMIS capabilities "that it was a given that PROMIS was used for a wide variety of purposes by intelligence agencies, including the real-time monitoring of stock transactions on all the world´s major financial markets". [4]

We are therefore dealing with a software that
a) Infiltrates computer and communication systems without being noticed.
b) Can manipulate data.
c) Is capable to track the global stock market trade in real time.

Point c is relevant to all that happened in connection with the never completely cleared up transactions that occurred just before September 11, [5] and of which the former chairman of the Deutsche Bundesbank Ernst Weltke said "could not have been planned and carried out without a certain knowledge". [6]

I specifically asked financial journalist Max Keiser, who for years had worked on Wall Street as a stock and options trader, about the put option trades. Keiser pointed out in this context that he "had spoken with many brokers in the towers of the World Trade Center around that time. I heard firsthand about the airline put trade from brokers at Cantor Fitzgerald days before." He then talked with me about an explosive issue, on which Ruppert elaborated in detail in Crossing the Rubicon.

Max Keiser: There are many aspects concerning these option purchases that have not been disclosed yet. I also worked at Alex Brown & Sons (ABS). Deutsche Bank bought Alex Brown & Sons in 1999. When the attacks occurred, ABS was owned by Deutsche Bank. An important person at ABS was Buzzy Krongard. I have met him several times at the offices in Baltimore. Krongard had transferred to become executive director at the CIA. The option purchases, in which ABS was involved, occurred in the offices of ABS in Baltimore. The noise which occurred between Baltimore, New York City and Langley was interesting, as you can imagine, to say the least.

Under consideration here is the fact that Alex Brown, a subsidiary of Deutsche Bank (where many of the alleged 9/11 hijackers handled their banking transactions - for example Mohammed Atta) traded massive put options purchases on United Airlines Company UAL through the Chicago Board Option Exchange (CBOE) - "to the embarrassment of investigators", as British newspaper The Independent reported. [7]

On September 12, the chairman of the board of Deutsche Bank Alex Brown, Mayo A Shattuck III, suddenly and quietly renounced his post, although he still had a three-year contract with an annual salary of several million US dollars. One could perceive that as somehow strange.

A few weeks later, the press spokesperson of the Central Intelligence Agency (CIA) at that time, Tom Crispell, declined all comments, when he was contacted for a report for Ruppert´s website From the Wilderness, and had being asked "whether the Treasury Department or FBI [Federal Bureau of Investigation] had questioned CIA executive director and former Deutsche Bank-Alex Brown CEO [chief executive officer], A B 'Buzzy' Krongard, about CIA monitoring of financial markets using PROMIS and his former position as overseer of Brown's 'private client' relations." [8]

Just before he was recruited personally by former CIA chief George Tenet for the CIA, Krongard supervised mainly private client banking at Alex Brown. [9]

In any case, after 9/11 on the first trading day, when the US stock markets were open again, the stock price of UAL declined by 43%. (The four aircraft hijacked on September 11 were American Airlines Flight 11, American Airlines Flight 77 and UAL flights 175 and 93.)

With his background as a former options trader, Keiser explained an important issue to me in that regard.

Max Keiser: Put options are, if they are employed in a speculative trade, basically bets that stock prices will drop abruptly. The purchaser, who enters a time-specific contract with a seller, does not have to own the stock at the time when the contract is purchased.

Related to the issue of insider trading via (put or call) options there is also a noteworthy definition by the Swiss economists Remo Crameri, Marc Chesney and Loriano Mancini, notably that an option trade may be "identified as informed" - but is not yet (legally) proven - "when it is characterized by an unusual large increment in open interest and volume, induces large gains, and is not hedged in the stock market". [10]

Open interest describes contracts which have not been settled (been exercised) by the end of the trading session, but are still open. Not hedged in the stock market means that the buyer of a (put or call) option holds no shares of the underlying asset, by which he might be able to mitigate or compensate losses if his trade doesn't work out, or phrased differently: one does not hedge, because it is unnecessary, since one knows that the bet is one, pardon, "dead sure thing." (In this respect it is thus not really a bet, because the result is not uncertain, but a foregone conclusion.)

In this case, the vehicle of the calculation was "ridiculously cheap put options which give the holder the ‘right' for a period of time to sell certain shares at a price which is far below the current market price - which is a highly risky bet, because you lose money if at maturity the market price is still higher than the price agreed in the option. However, when these shares fell much deeper after the terrorist attacks, these options multiplied their value several hundred times because by now the selling price specified in the option was much higher than the market price. These risky games with short options are a sure indication for investors who knew that within a few days something would happen that would drastically reduce the market price of those shares." [11]

Software such as PROMIS in turn is used with the precise intent to monitor the stock markets in real time to track price movements that appear suspicious. Therefore, the US intelligence services must have received clear warnings from the singular, never before sighted transactions prior to 9/11.

Of great importance with regard to the track, which should lead to the perpetrators if you were seriously contemplating to go after them, is this:

Max Keiser: The Options Clearing Corporation has a duty to handle the transactions, and does so rather anonymously - whereas the bank that executes the transaction as a broker can determine the identity of both parties.

But that may have hardly ever been the intention of the regulatory authorities when the track led to, amongst others, Alvin Bernard "Buzzy" Krongard, Alex Brown & Sons and the CIA. Ruppert, however, describes this case in Crossing the Rubicon in full length as far as possible. [12]

In addition, there are also ways and means for insiders to veil their tracks. In order to be less obvious, "the insiders could trade small numbers of contracts. These could be traded under multiple accounts to avoid drawing attention to large trading volumes going through one single large account. They could also trade small volumes in each contract but trade more contracts to avoid drawing attention. As open interest increases, non-insiders may detect a perceived signal and increase their trading activity. Insiders can then come back to enter into more transactions based on a seemingly significant trade signal from the market. In this regard, it would be difficult for the CBOE to ferret out the insiders from the non-insiders, because both are trading heavily." [13]

The matter which needs clarification here is generally judged by Keiser as follows:

Max Keiser: My thought is that many (not all) of those who died on 9/11 were financial mercenaries - and we should feel the same about them as we feel about all mercenaries who get killed. The tragedy is that these companies mixed civilians with mercenaries, and that they were also killed. So have companies on Wall Street used civilians as human shields maybe?

According to a report by Bloomberg published in early October 2001, the US Securities and Exchange Commission (SEC) began a probe into certain stock market transactions around 9/11 that included 38 companies, among them: American Airlines, United Airlines, Continental Airlines, Northwest Airlines, Southwest Airlines, Boeing, Lockheed Martin Corp., American Express Corp., American International Group, AXA SA, Bank of America Corp., Bank of New York Corp., Bear Stearns, Citigroup, Lehman Brothers Holdings Inc., Morgan Stanley, General Motors and Raytheon. [14]

So far, so good. In the same month, however, the San Francisco Chronicle newspaper reported that the SEC took the unprecedented step to deputize hundreds, if not even thousands of key stakeholders in the private sector for their investigation. In a statement that was sent to almost all listed companies in the US, the SEC asked the addressed companies to assign senior staff for the investigation, who would be aware of "the sensitive nature" of the case and could be relied on to "exercise appropriate discretion". [15]

In essence, it was about controlling information, not about provision and disclosure of facts. Such a course of action involves compromising consequences. Ruppert:

What happens when you deputize someone in a national security or criminal investigation is that you make it illegal for them to disclose publicly what they know. Smart move. In effect, they become government agents and are controlled by government regulations rather than their own conscience. In fact, they can be thrown into jail without a hearing if they talk publicly. I have seen this implied threat time after time with federal investigators, intelligence agents, and even members of United States Congress who are bound so tightly by secrecy oaths and agreements that they are not even able to disclose criminal activities inside the government for fear of incarceration. [16]

Among the reports about suspected insider trading which are mentioned in Crossing the Rubicon/From the Wilderness is a list that was published under the heading "Black Tuesday: The World's Largest Insider Trading Scam?" by the Israeli Herzliyya International Policy Institute for Counterterrorism on September 21, 2001:
 Between September 6 and 7, the CBOE saw purchases of 4,744 put options on United Airlines, but only 396 call options. Assuming that 4,000 of the options were bought by people with advance knowledge of the imminent attacks, these "insiders" would have profited by almost $5 million. On September 10, 4,516 put options on American Airlines were bought on the Chicago exchange, compared to only 748 calls. Again, there was no news at that point to justify this imbalance; again, assuming that 4,000 of these options trades represent "insiders", they would represent a gain of about $4 million. [The levels of put options purchased above were more than six times higher than normal.] No similar trading in other airlines occurred on the Chicago exchange in the days immediately preceding Black Tuesday. Morgan Stanley Dean Witter & Co, which occupied 22 floors of the World Trade Center, saw 2,157 of its October $45 put options bought in the three trading days before Black Tuesday; this compares to an average of 27 contracts per day before September 6. Morgan Stanley's share price fell from $48.90 to $42.50 in the aftermath of the attacks. Assuming that 2,000 of these options contracts were bought based upon knowledge of the approaching attacks, their purchasers could have profited by at least $1.2 million. Merrill Lynch & Co, with headquarters near the Twin Towers, saw 12,215 October $45 put options bought in the four trading days before the attacks; the previous average volume in those shares had been 252 contracts per day (a 1200% increase). When trading resumed, Merrill's shares fell from $46.88 to $41.50; assuming that 11,000 option contracts were bought by "insiders", their profit would have been about $5.5 million. European regulators are examining trades in Germany's Munich Re, Switzerland's Swiss Re, and AXA of France, all major reinsurers with exposure to the Black Tuesday disaster. (Note: AXA also owns more than 25% of American Airlines stock, making the attacks a "double whammy" for them.) [17]

Concerning the statements of the former chairman of the Deutsche Bundesbank Ernst Welteke, their tenor in various press reports put together is as follows:

German central bank president Ernst Welteke later reports that a study by his bank indicates, "There are ever clearer signs that there were activities on international financial markets that must have been carried out with the necessary expert knowledge," not only in shares of heavily affected industries such as airlines and insurance companies, but also in gold and oil. [Daily Telegraph, 9/23/2001] His researchers have found "almost irrefutable proof of insider trading". [Miami Herald, 9/24/2001] "If you look at movements in markets before and after the attack, it makes your brow furrow. But it is extremely difficult to really verify it." Nevertheless, he believes that "in one or the other case it will be possible to pinpoint the source". [Fox News, 9/22/2001] Welteke reports "a fundamentally inexplicable rise" in oil prices before the attacks [Miami Herald, 9/24/2001] and then a further rise of 13 percent the day after the attacks. Gold rises nonstop for days after the attacks. [Daily Telegraph, 9/23/2001] [18]

Related to those observations, I sent a request via e-mail to the press office of the Deutsche Bundesbank on August 1, 2011, from which I was hoping to learn:
How did the Bundesbank deal with this information? Did US federal agencies ask to see the study? With whom did the Bundesbank share this information? And additionally: 1. Can you confirm that there is such a study of the Bundesbank concerning 9/11 insider trading, which was carried out in September 2001?
2. If Yes: what is the title?
3. If Yes: who were the authors?
4. If Yes: has the study ever been made available to the public?

On August 2, I was then informed: "Your mail has been received by us and is being processed under the number 2011 / 011551." Ultimately, however, the press office of the Deutsche Bundesbank was only available for an oral explanation on the phone. With this explanation, I then turned to the press office of the federal financial regulator in Germany, the Bundesanstalt fur Finanzdienstleistungsaufsicht, BaFin, with the following e-mail - and that because of obvious reasons:

Yesterday, I sent a request (see end of this e-mail) to the press office of the Deutsche Bundesbank relating to insider trading connected to the terrorist attacks on September 11, 2001, and respectively relating to an alleged study carried by the Deutsche Bundesbank. The request carries the reference number 2011 / 011551.

The press office or respectively Mr Peter Trautmann was only available for an oral explanation. I repeat this now, because it is related to your entity. This will be followed by my further questions.

According to an oral explanation from the press office of the Deutsche Bundesbank, there has never been a detailed and official study on insider trading from the Bundesbank. Rather, there has been probably ad-hoc analysis with corresponding charts of price movements as briefings for the Bundesbank board. In addition, it would have been the duty of the Bundesfinanzaufsicht to investigate this matter. The press office of the Bundesbank was also not willing to give out any written information, not even after my hint that this alleged study by the Bundesbank has been floating around the Internet for years without any contradiction. That was the oral information from the Bundesbank press office, or respectively from Mr Peter Trautmann.

Now my questions for you:
1. Has the BaFin ever investigated the 9/11 insider trading?
2. With what result? Have the results been made public?
3. Have there not been any grounds for suspicion that would have justified an investigation, for example as damaged enterprise: Munich Re, and as buyers of put options of UAL's United Airlines Company: Deutsche Bank/Alex Brown?
4. Has the Deutsche Bundesbank ever enquired with BaFin what information they have regarding the 9/11 insider trading - for example for the creation of ad-hoc analysis for the Bundesbank?
5. Have the US federal agencies ever inquired if the BaFin could cooperate with them in an investigation?
Could you reply to me in writing, unlike the Deutsche Bundesbank, please? I would be very grateful for that!

The next day I did indeed receive an e-mail concerning this topic from Anja Engelland, the press officer of the BaFin in which she answered my questions as follows:

1. Yes, the former Bundesaufsichtsamt fur Wertpapierhandel, BAWe (federal supervisory for securities trading), has carried out a comprehensive analysis of the operations.
2. As a result, no evidence of insider trading has been found. Their approach and results have been published by the BAWe or BaFin in the annual reports for the years 2001 (cf S 26/27) and 2002 (cf p 156 above first paragraph). Here are the links. [See here and here.]
3. See annual reports 2001 and 2002. Put options on United Airlines were not traded on German stock exchanges (the first EUREX options on US equities were introduced only after the attacks on 9/11/2001); there were warrants on UAL and other US stocks, but those traded only in low volumes.
4. I personally do not know about such a request. Furthermore, the Bundesbank itself would have to comment on this.
5. BaFin is fundamentally entitled to the exchange of information with foreign supervisory authorities, like SEC, on the basis of written agreements, so-called memoranda of understanding (MoU). Regarding potential inquiries from foreign supervisory authorities, the BaFin can unfortunately not comment, this would be a matter of respective authority. For this I ask for understanding.

Then I wrote another brief note to BaFin, "in order to prevent any misunderstanding: your answers refers, as far as I understand, solely to the financial markets in Germany and Frankfurt, or not?" The reply from BaFin:

The answers refer to the German financial market as a whole and not only on the Frankfurt Stock Exchange. In terms of the assessment of foreign financial markets, the relevant authorities are the competent points of contact.

In my inquiries, I mentioned, among other things, a scientific study by US economist Allen M Poteshman from the University of Illinois at Urbana-Champaign, which had been carried out in 2006 regarding the put option trading around 9/11 related to the two airlines involved, United Airlines and American Airlines. Poteshman came to this conclusion: "Examination of the option trading leading up to September 11 reveals that there was an unusually high level of put buying. This finding is consistent with informed investors having traded options in advance of the attacks." [19]

Another scientific study was conducted by the economists Wong Wing-Keung (Hong Kong Baptist University, HKBU), Howard E Thompson (University of Wisconsin) and Kweehong Teh (National University of Singapore, NUS), whose findings were published in April 2010 under the title "Was there Abnormal Trading in the S&P 500 Index Options Prior to the September 11 Attacks?"

Motivated by the fact that there had been many media reports about possible insider trading prior to 9/11 in the option markets, the authors looked in this study at the Standard & Poor's 500 Index (SPX Index Options), in particular with a focus on strategies emanating from a bear market, namely those under the labels

"Put Purchase," "Put Bear Spread" and "Naked ITM Call Write", as each of these are in accordance with the assumption that one would be betting on a general bear market if one wanted to profit in anticipation of the 9/11 event. [20]

Along these lines, the authors refer to an article which Erin E Arvedlund published on October 8, 2001, in Barron's, the heading of which suggested precisely that thesis: "Follow the money: Terror plotters could have benefited more from the fall of the entire market than from individual stocks." [21]

Basically, Wong, Thompson and Teh came to the conclusion "that our findings show that there was a significant abnormal increase in the trading volume in the option market just before the 9-11 attacks in contrast with the absence of abnormal trading volume far before the attacks".

More specifically, they stated, "Our findings from the out-of-the-money (OTM), at-the-money (ATM) and in-the-money (ITM) SPX index put options and ITM SPX index call options lead us to reject the null hypotheses that there was no abnormal trading in these contracts before September 11th."

Instead, they found evidence for "abnormal trading volume in OTM, ATM and ITM SPX index put options" for September 2001, and also in "ITM-SPX index call options" for the same month. "In addition, we find that there was evidence of abnormal trading in the September 2001 OTM, ATM and ITM SPX index put options immediately after the 9-11 attacks and before the expiration date. This suggests that owning a put was a valuable investment and those who owned them could sell them for a considerable profit before the expiration date."

From all of this, they took the position that whilst they couldn't definitively prove that insiders were active in the market, "our results provide credible circumstantial evidence to support the insider trading claim". [22]

Disambiguation: "in the money" means that the circumstances arise on which the owner of a put option is betting - the market price of the underlying asset, for example a stock (or in this case an index of shares), is lower at that moment compared to the price at the time when the transaction took place. "At the money" means that the price of the underlying asset has remained equal or nearly equal. And "out-of-the-money" means that the price of the underlying asset has gone up, so the opposite of what the owner of the put option was betting on took place. "In the money": win. "Out of the money": loss.

There are also ITM, ATM and OTM options both for trading strategies with put and call options, depending on which kind of risk one would like to take. For example, according to Wong, Thomson and Teh, the "Put-Purchase Strategy" in the case of a downward movement of the underlying asset "is a cheaper alternative to short-selling of the underlying asset and it is the simplest way to profit when the price of the underlying asset is expected to decline".

The use of the OTM put option compared to the ITM put option, however, offers "both higher reward and higher risk potentials (...) if the underlying asset falls substantially in price. However, should the underlying asset decline only moderately in price, the ITM put often proves to be the better choice (...) because of the relative price differential."

That is why speculators would fare best, if they bought ITM put options, "unless the speculators would expect a very substantial decline in the price of the underlying asset." [23]

After they calculated such strategies in the light of the available trading data in the CBOE relating to 9/11, the three economists ultimately do not accept a possible counter-argument that their results could be attributed to the fact that the stock markets were generally falling and that there had already been a negative market outlook. Finally they pointed out: "More conclusive evidence is needed to prove definitively that insiders were indeed active in the market. Although we have discredited the possibility of abnormal volume due to the declining market, such investigative work would still be a very involved exercise in view of the multitude of other confounding factors," such as confusing trading strategies, "intentionally employed by the insiders" in order to attract less attention. [24]

That would be - and if only to invalidate these scientific results once and for all - primarily a task for the SEC, the FBI and other governmental authorities of the United States. However, we will have to wait for this in vain.

I think that not less worthy of a mention is an article that the French financial magazine Les Echos published in September 2007 about a study conducted by two independent economics professors from the University of Zurich, Marc Chesney and Loriano Mancini. Journalist Marina Alcaraz summarized the content of the findings in Les Echos with these words and with these explanations by Professor Chesney, which I for the first time translated into German (and do now translate from French into English):

"The atypical volumes, which are very rare for specific stocks lead to the suspicion of insider trading." Six years after the attacks on the World Trade Center this is the disturbing results of a recent study by Marc Chesney and Loriano Mancini, professors at the University of Zurich. The authors, one of them a specialist in derivative products, the other a specialist in econometrics, worked on the sales options that were used to speculate on the decline in the prices of 20 large American companies, particularly in the aerospace and financial sector.

Their analysis refers to the execution of transactions between the 6th and 10th of September 2001 compared to the average volumes, which were collected over a long period (10 years for most of the companies). In addition, the two specialists calculated the probability that different options within the same sector in significant volumes would be traded within a few days. "We have tried to see if the movements of specific stocks shortly before the attacks were normal." We show that the movements for certain companies such as American Airlines, United Airlines, Merrill Lynch, Bank of America, Citigroup, Marsh & McLehnan are rare from a statistical point of view, especially when compared to the quantities that have been observed for other assets like Coca-Cola or HP," explains Marc Chesney, a former Professor at the HEC and co-author of Blanchiment et financement du terrorisme (Money laundering and financing of terrorism), published by Editions Ellipses. "For example 1,535 put option contracts on American Airlines with a strike of $30 and expiry in October 2001 were traded on September 10th, in contrast to a daily average of around 24 contracts over the previous three weeks. The fact that the market was currently in a bear market is not sufficient to explain these surprising volumes."

The authors also examined the profitability of the put options and trades for an investor who acquired such a product between the 6th and 10th September. "For specific titles, the profits were enormous." "For example, the investors who acquired put options on Citigroup with an expiry in October 2001 could have made more than $15 million profit," he said. On the basis of the connection of data between volumes and profitability, the two authors conclude that "the probability that crimes by Insiders (Insider trading) occurred , is very strong in the cases of American Airlines, United Airlines, Merrill Lynch, Bank of America, Citigroup and JP Morgan. "There is no legal evidence, but these are the results of statistical methods, confirming the signs of irregularities." [25]

As Alcaraz continued to state for Les Echos, the study by Chesney/Mancini about possible insider trading related to the 9/11 attacks was not the first of its kind; but it was in sharp contrast to the findings of the US Securities and Exchange Commission SEC and the 9/11 Commission, since they classified the insider trading as negligible - the trades in question had no connection to 9/11 and had "consistently proved innocuous".

Different in the assessment is also the scientific work that Chesney and Mancini had published together with Remo Crameri in April 2010 at the University of Zurich, "Detecting Informed Trading Activities in the option markets." In the segment that is dedicated to the terror attacks of 9/11, the three authors come to the conclusion, that there had been notable insider trading shortly before the terrorist attacks on September 11 that was based on prior knowledge.

Without elaborating on the detailed explanation of the mathematical and statistical method, which the scientific trio applied during the examination of the put option transactions on the CBOE for the period between 1996 and 2006, I summarize some of their significant conclusions.

"Companies like American Airlines, United Airlines, Boeing" - the latter company is a contractor of the two airlines as aircraft manufacturer - "and to a lesser extent, Delta Air Lines and KLM seem to have been targets for informed trading activities in the period leading up to the attacks. The number of new put options issued during that period is statistically high and the total gains realized by exercising these options amount to more than $16 million. These findings support the results by Poteshman (2006) who also reports unusual activities in the option market before the terrorist attacks." [26]

In the banking sector, Chesney, Crameri and Mancini found five informed trading activities in connection to 9/11. "For example the number of new put options with underlying stock in Bank of America, Citigroup, JP Morgan and Merrill Lynch issued in the days before the terrorist attacks was at an unusually high level. The realized gains from such trading strategies are around $11 million." [27]

For both areas, the aviation and the banking sector, the authors state that "in nearly all cases the hypothesis", that the put options were not hedged, "cannot be rejected". [28]

Regarding the options traded on EUREX, one of the world's largest trading places for derivatives, which in 1998 resulted from the merger between the German and Swiss futures exchanges DTB and SOFFEX, Chesney, Mancini and Crameri focused on two reinsurance companies, which incurred costs in terms of billions of dollars in connection with the World Trade Center catastrophe: Munich Re and Swiss Re.

On the basis of EUREX trading data provided by Deutsche Bank, the three scientists detected one informed option trade related to Munich Re, which occurred on August 30, 2001. The authors write: "The detected put option with underlying Munich Re matured at the end of September 2001 and had a strike of € 320 (the underlying asset was traded at € 300, 86 on August 30th). That option shows a large increment in open interest of 996 contracts (at 92.2% quintile of its two-year empirical distribution) on August 30th.

Its price on that day was € 10, 22. ... On the day of the terrorist attacks, the underlying stock lost more than 15% (the closing price on September 10th was € 261, 88 and on September 11th € 220, 53) and the option price jumped to € 89, 56, corresponding to a return of 776% in eight trading days. ... The gains ... related to the exercise of the 996 new put options issued on August 30th correspond to more than 3.4 million." Similar is true, according to the authors, for one informed option trade on Swiss Re on August 20, 2001 with "a return of 4,050% in three trading weeks", or "more than € 8 million." [29]

In a new version of their study that was published on September 7, 2011, the authors stuck to their findings from April 2010. They added the emphasis that in no way the profits gained with the put options to which they point could have been achieved due to sheer fortunate coincidence, but that in fact they were based on prior knowledge which had been exploited. [30]

With those results in terms of what went on at the EUREX according to Chesney, Crameri and Mancini, I again addressed the BaFin, which had written to me that for the financial centers in Germany insider trading around 9/11 could be excluded, and asked:

How does this go with your information that the federal supervisory for securities trading (BAWe) could in its comprehensive analysis not find evidence for insider trading? Do the authors, so to speak, see ghosts with no good reason?

In addition, I stated:

If it is true what Chesney, Crameri and Mancini write, or if you at the BaFin cannot (ad hoc) refute it, would this then cause the BaFin to thoroughly investigate the matter again? If the findings of Chesney, Crameri, and Mancini were true, this would constitute illegal transactions relating to a capital crime, which has no status of limitations, or not?

In case that a need for clarification had arisen at the BaFin, I added Professor Chesney to my e-mail-inquiry in the "carbon copy" - address field, as because these were the results of his scientific work.

The response that I received from BaFin employee Dominika Kula was as follows:

As I already told you in my e-mail, the former federal supervisory for securities trading (BAWe) carried out a comprehensive analysis of the operations in 2001. As a result, no evidence of insider trading has been found. For clarification purposes, I wish to point out that violations of statutory provisions of securities or criminal law can never be excluded with absolute certainty. In order to pursue and prosecute such matters concrete evidence of an unlawful act is required ... Such evidence does not exist here.

With regard to the sources you mentioned, I ask for understanding that I can neither comment on scientific analyses, nor on reviews by third parties.

Regarding the statutes of limitations for offences relating to the violation insider trading regulations trading I can give you the following information: A violation of the law to prohibit insider trading is punishable with imprisonment up to 5 years or with fines. The statutes of limitations applied for crimes carrying this kind of penalty (section 78 paragraph 3 No. 4 Penal Code) are five years. These limitations are described in the statutes of limitations (§§ 78 et seq.) (Criminal Code).

In addition, I turned to the EUREX with three questions:
1. How do you as EUREX comment on the findings of Messrs Chesney, Mancini and Crameri?
2. Did you at EUREX perceive the particular trading in Munich Re and Swiss Re it in any way as strange?
3. Have domestic (eg BAWe and BaFin) or foreign (such as the U.S. Securities and Exchange Commission) authorities ever inquired if there may have been evidence of insider trading via the EUREX in connection with the 9/11 attacks?

I subsequently received the following response from Heiner Seidel, the deputy head of the press office of the Deutsche Borse in Frankfurt.

We do not give you a public written response on behalf of the Deutsche Börse or Eurex regarding the topics of your inquiry. This is for the following reason: the trade monitoring agency (HüSt) is part of the Exchange, but it is independent and autonomous. Their investigations are confidential and are carried out in close coordination with the BaFin. They are never public, a request which HüSt is therefore not meaningful.

I leave it to the reader to draw his/her conclusions from these two replies from the press offices of BaFin and Deutsche Borse. Regarding the topic of option trades related to 9/11, I once more talked with Swiss historian Dr Daniele Ganser ("Operation Gladio"), by asking him this time about the importance of those put options, which were traded shortly before the attacks of September 11, 2001.

Daniele Ganser: This is an important point. This is about demonstrating that there was insider trading on the international stock exchanges before 11 September. Specifically put options, ie speculation on falling stock prices were traded. Among the affected stocks were United Airlines and American Airlines, the two airlines involved in the attacks.

A colleague of mine, Marc Chesney, professor at the Institute of banking at the University of Zurich, has examined these put options. You first of all have to check if there may have been international speculation that the aviation industry would be experiencing a weak period and whether accordingly also put options on Singapore Airlines, Lufthansa and Swiss were bought. This was not the case.

Very significant put option trades were only transacted for these two airlines involved in the attacks. Secondly, you must examine the ratio of put options to call options and look if they had also been purchased to a similarly significant extent that would constitute speculations on rising stock prices. And that is also not the case. There were only significant put options and only significant transactions for United Airlines and American Airlines.

Now you need to look further in order to see who actually bought the put options, because that would be the insider who made millions on September 11. Most people are unaware that money was also earned with the attacks on September 11. The Security and Exchange Commission, SEC, the Securities and Exchange Commission of the United States, however, does not publish the information on who bought the put options, because you can do this anonymously. It is disturbing that this data is not made public.

What you have is the 9/11 Commission report, and here it is pointed out , that there has been insider trading, but that this insider trading cannot be traced to [al-Qaeda leader] Osama bin Laden, which means that it is highly unlikely that it had been Bin Laden.

Question: If this is not pursued any further, what does it mean?

Daniele Ganser: This means that the investigation of the terrorist attacks was incomplete, and always at the point where there are contradictions to the SURPRISE story, no further investigations are made. It looks very much as if one wants to examine only one story, the investigation is therefore one-sided. But this does not only apply to the put options. [31]

Interestingly enough, when Dr Ganser points out in his reply that this important data is not published, it is actually only half of the truth. Why? The answer is very simple and odd at the same time: David Callahan, the editor of the US magazine SmartCEO, filed a request to the SEC about the put options which occurred prior to September 11 within the framework of the Freedom of Information Act (FOIA). The SEC informed Callahan in its reply of December 23, 2009 under the number "09 07659-FOIA" as follows:

This letter is in response to your request seeking access to and copies of the documentary evidence referred to in footnote 130 of Chapter 5 of the September 11 (9/11) Commission Report... We have been advised that the potentially responsive records have been destroyed. [32]

Therefore, we will unfortunately never know exactly how the SEC and the 9/11 Commission came to their conclusions regarding the 9/11 put options trading for their final report, because relevant documents were not only held back, but also destroyed - and that in spite of an agreement between the SEC and the National Archive of the United States, in which the SEC has agreed to keep all records for at least 25 years. [33] 

The 9/11 Commission report wrote this in footnote 130 of Chapter 5, which briefly focuses on the alleged insider trading:

Highly publicized allegations of insider trading in advance of 9 / 11 generally rest on reports of unusual pre-9/11 trading activity in companies whose stock plummeted after the attacks. Some unusual trading did in fact occur, but each such trade proved to have an innocuous explanation. For example, the volume of put options - investments that pay off only when a stock drops in price - surged in the parent companies of United Airlines on September 6 and American Airlines on September 10 - highly suspicious trading on its face.

Yet, further investigation has revealed that the trading had no connection with 9/11. A single US-based institutional investor with no conceivable ties to al-Qaeda purchased 95 percent of the UAL puts on September 6 as part of a trading strategy that also included buying 115,000 shares of American on September 10. Similarly, much of the seemingly suspicious trading in American on September 10 was traced to a specific US-based options trading newsletter, faxed to its subscribers on Sunday, September 9, which recommended these trades.

These examples typify the evidence examined by the investigation. The SEC and the FBI, aided by other agencies and the securities industry, devoted enormous resources to investigating this issue, including securing the cooperation of many foreign governments. These investigators have found that the apparently suspicious consistently proved innocuous. (Joseph Cella interview (Sept 16, 2003; May 7, 2004; May 10-11, 2004); FBI briefing (Aug 15, 2003); SEC memo, Division of Enforcement to SEC Chair and Commissioners, "Pre-September 11, 2001 Trading Review," May 15, 2002; Ken Breen interview (Apr. 23, 2004); Ed G. interview (Feb. 3, 2004).

The author Mark H Gaffney commented on this finding of

"innocuousness":

Notice ... the commission makes no mention in its footnote of the 36 other companies identified by the SEC in its insider trading probe. What about the pre-9/11 surge in call options for Raytheon, for instance, or the spike in put options for the behemoth Morgan Stanley, which had offices in WTC 2? The 9/11 Commission Report offers not one word of explanation about any of this. The truth, we must conclude, is to be found between the lines in the report's conspicuous avoidance of the lion's share of the insider trading issue.

Indeed, if the trading was truly "innocuous", as the report states, then why did the SEC muzzle potential whistleblowers by deputizing everyone involved with its investigation? The likely answer is that so many players on Wall Street were involved that the SEC could not risk an open process, for fear of exposing the unthinkable. This would explain why the SEC limited the flow of information to those with a "need to know", which, of course, means that very few participants in the SEC investigation had the full picture.

It would also explain why the SEC ultimately named no names. All of which hints at the true and frightening extent of criminal activity on Wall Street in the days and hours before 9/11. The SEC was like a surgeon who opens a patient on the operating room table to remove a tumor, only to sew him back up again after finding that the cancer has metastasized through the system.

At an early stage of its investigation, perhaps before SEC officials were fully aware of the implications, the SEC did recommend that the FBI investigate two suspicious transactions. We know about this thanks to a 9/11 Commission memorandum declassified in May 2009 which summarizes an August 2003 meeting at which FBI agents briefed the commission on the insider trading issue. The document indicates that the SEC passed the information about the suspicious trading to the FBI on September 21, 2001, just ten days after the 9/11 attacks.

Although the names in both cases are censored from the declassified document, thanks to some nice detective work by Kevin Ryan we know whom (in one case) the SEC was referring to. The identity of the suspicious trader is a stunner that should have become prime-time news on every network, world-wide. Kevin Ryan was able to fill in the blanks because, fortunately, the censor left enough details in the document to identify the suspicious party who, as it turns out, was none other than Wirt Walker III, a distant cousin to then-president G W Bush.

Several days before 9/11, Walker and his wife Sally purchased 56,000 shares of stock in Stratesec, one of the companies that provided security at the World Trade Center up until the day of the attacks. Notably, Stratesec also provided security at Dulles International Airport, where AA 77 took off on 9/11, and also security for United Airlines, which owned two of the other three allegedly hijacked aircraft. At the time, Walker was a director of Stratesec. Amazingly, Bush's brother Marvin was also on the board.

Walker's investment paid off handsomely, gaining $50,000 in value in a matter of a few days. Given the links to the World Trade Center and the Bush family, the SEC lead should have sparked an intensive FBI investigation. Yet, incredibly, in a mind-boggling example of criminal malfeasance, the FBI concluded that because Walker and his wife had "no ties to terrorism ... there was no reason to pursue the investigation." The FBI did not conduct a single interview. [34]

For this translation, I asked Kevin Ryan via e-mail if he could send me a link for his "nice detective work". Ryan, who's in my humble opinion one of roughly 10 people around the world who have to be taken seriously regarding 9/11, replied:

You are referring to my paper "Evidence for Informed Trading on the Attacks of September 11." [See here.] The following two references from the paper are relevant to what you are describing. [2] 9/11 Commission memorandum entitled "FBI Briefing on Trading", prepared by Doug Greenburg, 18 August 2003, [22].

The 9/11 Commission memorandum that summarized the FBI investigations refers to the traders involved in the Stratesec purchase. From the references in the document, we can make out that the two people had the same last name and were related. This fits the description of Wirt and Sally Walker, who were known to be stock holders in Stratesec. Additionally, one (Wirt) was a director at the company, a director at a publicly traded company in Oklahoma (Aviation General), and chairman of an investment firm in Washington, DC (Kuwam Corp). Here are two other recent articles on Stratesec and its operators. [See here and here.]

The stock of Stratesec, I should add by myself, increased in value from $0.75 per share on September 11 to $1.49 per share when the market re-opened on September 17. As a firm that provides technology-based security for large commercial and government facilities, Stratesec benefited from the soaring demand of security companies right after 9/11.

It is also remarkable what Ryan wrote to me regarding a company on which he did some research, too: Viisage Corp, another high-tech security firm.

Kevin Ryan: In late 2005, George Tenet became a director for Viisage, which had been flagged by the SEC for 9/11 trading but never investigated. Viisage was led by Roger LaPenta, formerly of Lockheed.

Seven months later, in 2006, FBI director Louis Freeh also joined the Viisage board. One might think that when both the CIA director (on 9/11) and the FBI director (from 1993 to June 2001) joined a company suspected of 9/11 insider trading, we might want to go back and actually investigate the SEC's flagging of that company. But, of course, that was not the case. In 2009, "Bandar Bush" hired Freeh as his personal attorney.

Freeh is nowadays the bankruptcy trustee of the alleged market manipulator MF Global. And about his client, the former Saudi ambassador Prince Bandar, I should add that we know for sure that he bankrolled indirectly via his wife two of the alleged would-be 9/11 hijackers, Khalid Al-Mihdhar and Nawaf Al-Hazmi. [35]

But let's get back to the subject of destruction. On September 11, not only human life, aircraft and buildings were destroyed in New York City, but also data on computers and in archives. For example, several federal agencies occupied space in Building 7 of the World Trade Center, including the Securities and Exchange Commission on floors 11 to 13.

Those and other data could have given information about the alleged 9/11 insider trading (though it seems to be very unlikely that no backup existed elsewhere independent of the local computer systems). In fact, some technology companies were commissioned to recover damaged hard disks, which had been recovered from the debris and dust of Ground Zero.

One of these companies was the English company group Convar, more precisely: their data rescue center in the German city Pirmasens. Erik Kirschbaum from the news agency Reuters reported in December 2001 that Convar had at that time successfully restored information from 32 computers, supporting "suspicions that some of the 911 transactions were illegal".

'The suspicion is that inside information about the attack was used to send financial transaction commands and authorizations in the belief that amid all the chaos the criminals would have, at the very least, a good head start,' says Convar director Peter Henschel." [36] Convar received the costly orders - according to Kirschbaum´s report the companies had to pay between $20,000 and $30,000 per rescued computer - in particular from credit card companies, because: "There was a sharp rise in credit card transactions moving through some computer systems at the WTC shortly before the planes hit the twin towers. This could be a criminal enterprise - in which case, did they get advance warning? Or was it only a coincidence that more than $100 million was rushed through the computers as the disaster unfolded?" [37]

The companies for which Convar was active cooperated with the FBI. If the data were reconstructed they should have been passed on to the FBI, and the FBI, according to its statutory mandate, should have initiated further investigation based on the data to find out who carried out these transactions. Henschel was optimistic at the time that the sources for the transactions would come to light.

Richard Wagner, a Convar employee, told Kirschbaum that "illegal transfers of more than $100 million might have been made immediately before and during the disaster. 'There is a suspicion that some people had advance knowledge of the approximate time of the plane crashes in order to move out amounts exceeding $100 million,' he says. 'They thought that the records of their transactions could not be traced after the main frames were destroyed'." [38]

Wagner's observation that there had been "illegal financial transactions shortly before and during the WTC disaster" matches an observation which Ruppert describes in Crossing the Rubicon. Ruppert was contacted by an employee of Deutsche Bank, who survived the WTC disaster by leaving the scene when the second aircraft had hit its target.

According to the employee, about five minutes before the attack the entire Deutsche Bank computer system had been taken over by something external that no one in the office recognized and every file was downloaded at lightning speed to an unknown location. The employee, afraid for his life, lost many of his friends on September 11, and he was well aware of the role which the Deutsche Bank subsidiary Alex Brown had played in insider trading. [39]

I was curious and wanted more information from Convar regarding their work on the WTC-computer hard drives, but also about the statements made by Peter Henschel and Richard Wagner. Thus, I contacted the agency which represents Convar for press matters, with a written request. But their agency "ars publicandi" informed me swiftly:

Due to time constraints, we can currently offer you neither information nor anyone on the part of our client to talk to regarding this requested topic.

I also approached KrollOntrack, a very interesting competitor of Convar in writing. Ontrack Data Recovery, which also has subsidiaries in Germany, was purchased in 2002 by Kroll Inc - "one of the nation's most powerful private investigative and security firms, which has long-standing involvement with executive protection US government officials including the president. This would require close liaison with the Secret Service." [40]

At the time of the 9/11 attacks, a certain Jerome Hauer was one of the managing directors at Kroll Inc. He had previously established the crisis center for the mayor of New York City as director of the Office of Emergency Management (OEM), which occupied office space on the 23rd floor of the WTC Building 7. Hauer helped former FBI agent John O'Neill to get the post of the head of Security Affairs at the WTC, and spent the night of September 11 with O'Neill in New York before the latter lost his life on September 11 in the WTC. Hauer was most likely involved in the planning of "Tripod II", the war game exercise at the port of New York City. [41]

Therefore, I found it appealing to uncover some more details of this aspect, or, more accurately to find out if Ontrack or KrollOntrack had received an order in 2001 or after to rescue computer hard drives from the WTC. The answer I received from KrollOntrack said:

Kroll Ontrack was not at the site of the data recovery - the devices at the Twin Towers have been completely destroyed or vaporized. The firm Kroll was, however, at that time active in the field of computer-forensic investigations, securing devices in the surrounding buildings.

In essence, these two inquiries did not help me at all. If anything, a further question arose: why did KrollOntrack send me a response, where it was really obvious that the content did not match the facts? After all, I had written in my inquiry that Convar had received orders to restore damaged computer hard drives from the World Trade Center.

I sent a new inquiry, attaching a link for Erik Kirschbaum's Reuters article and additional cinematic reports on Convar's which showed that some of the WTC disks had not been "completely destroyed or vaporized". I stated to KrollOntrack: "Your answer does not seem to match the facts, when it comes to 'completely destroyed or vaporized'. Will you still stick to your answer?"

KrollOntrack then replied that their previously given assessment constituted "not a statement, but an opinion".

I do not find this assessment worthless, because it is in line with the knowledge of the general public and can easily be refuted in argumentum in contrario by Convar´s activities.

One film report to which I referred to in my second inquiry to KrollOntrack originated from the German television journal Heute-Journal broadcast on March 11, 2002, on ZDF, and the other from the Dutch TV documentary Zembla, broadcast on September 10, 2006.

The ZDF report showed that Convar received the WTC disks from the US Department of Defense and that Convar had managed until March 2002 to recover more than 400 hard drives. It also reported that the private companies that employed Convar had paid between $25,000 and $50,000 per hard drive. In the TV documentary Zembla, Convar essentially maintained its position as it had been reported by Erik Kirschbaum in 2001.

Obviously, in connection with 9/11 there has not only been insider trading via put options, but there is additional evidence that there have been illegal financial transactions via credit cards through which more than 100 million US dollars were removed from the WTC computer systems.

Those occurred shortly before and during the WTC disaster. It remains unclear what the FBI did later on with the data recovered by Convar. On the other hand, it may have been not very much, as can be seen from a memorandum from the 9/11 Commission, which was released in May 2009.

The 9/11 Commission asked the FBI about the use of credit cards for insider dealing. On the basis of the information provided by the FBI, the commission came to the conclusion that no such activity occurred because "the assembled agents expressed no knowledge of the reported hard-drive recovery effort or the alleged scheme" - but above all "everything at the WTC was pulverized to near powder, making it extremely unlikely that any hard-drives survived". [42]

The activities of Convar, however, prove the exact opposite.

But it gets even better. According to Zembla, the FBI was directly involved with the data rescue efforts of Convar. And on top of it, the broadcast of Heute-Journal reported that Convar worked in that "highly sensitive" matter with several federal agencies of the United States government.

So there have been ample indications for insider trading based on foreknowledge of the attacks, but there are very few hard facts as Catherine Austin Fitts, a former managing director and member of the board of the Wall Street investment bank Dillon, Read & Co, Inc (now part of UBS), pointed out when I talked with her about this topic.

Ms Fitts, what are your general thoughts related to the alleged 9/11-insider trading?

Catherine Austin Fitts: Well, I've never been able to see concrete evidence that the insider trading has been proved. There's a lot of anecdotal information from investment bankers and people in the investment community that indicate that there was significant insider trading, particularly in the currency and bond markets, but again it hasn't been documented.

I think around situations like 9/11 we've seen things that can only be explained as insider trading. Therefore, it wouldn't surprise me if it turns out the allegations are true, because my suspicion is that 9/11 was an extremely profitable covert operation and a lot of the profits came from the trading. It wouldn't even surprise me if it turns out that the Exchange Stabilization Fund traded it and that some of the funding for the compensation fund for the victims came from the ESF.

Insider trading happens around these kinds of events, but if you really want to produce evidence of insider trading, you need the subpoena powers of the SEC, and of course we know that they haven't exercised them. If anything, right after 9/11, the government settled a significant amount of cases I presume because a lot of the documents were destroyed by the destruction of WTC building number 7, where the SEC offices and other governmental investigation offices were. [43]

Fitts, who had written a longer essay in 2004 related to this, replied to my question about who had benefited from 9/11:

Catherine Austin Fitts: 9/11 was extraordinarily profitable for Wall Street, they of course got a kind of "Get Out of Jail Free card" as I've just described. In addition, the largest broker of government bonds, Cantor Fitzgerald, was destroyed, and there was a great deal of money missing from the federal government in the prior four or five years. If you look at the amount of funds involved, it is hard to come to a conclusion other than massive securities fraud was involved, so I find it very interesting that this happened. [44]

A short explanation: Cantor Fitzgerald's headquarters were located in the North Tower of the WTC (floors 101-105). On 9/11, the company lost nearly two-thirds of its entire workforce, more than any other tenant in the WTC. (Also two other government bonds brokers, Garbon Inter Capital and Eurobrokers, occupied office space in the WTC towers that were destroyed.) Back to Fitts and the question: "Cui bono 9/11?"

Catherine Austin Fitts: In addition, the federal government took the position that they couldn't produce audited financial statements after 9/11, because they said the office at the Pentagon that produced financial statements was destroyed. Now given what I know of the federal set up of financial statements, I am skeptical of that statement.

But needless to say, if you take the government on its word, you had another "Get Out of Jail Free card" for four trillion dollars and more missing from the federal government. So if you're just looking at the financial fraud angle, there were a lot of parties that benefited from 9/11. But then of course what 9/11 did, it staged the passage of the Patriot Act and a whole series of laws and regulations that I collectively refer to as "The Control on Concentration of Cash Flow Act." It gave incredible powers to centralize.

In addition, if you look at monetary policies right after 9/11 - I remember I was over in the City of London driving around with a money manager and his phone rang and he answered it on his speaker phone. It was somebody on Wall Street who he hadn't talked to since before 9/11, and he said to him: "Oh Harry, I am so sorry about what has happened, it must have been very traumatic." And the guy said: "Don't be ridiculous! We were able to borrow cheap short and invest long, we're running a huge arbitrage, we're making a fortune, this is the most profitable thing that ever happened to us!" - So you could tell the monetary policies and sort of insider games were just pumping profits into the bank at that time, so that was very profitable.

But of course the big money was used for a significant movement of the military abroad and into Afghanistan and then into Iraq ... You could see that the country was being prepared to go to war. And sure enough, 9/11 was used as a justification to go to war in Afghanistan, to go to war in Iraq, and commit a huge number of actions, and now much of the challenges about the budget are the result of extraordinary expenditures on war including in Afghanistan and Iraq and the costs of moving the army abroad and engaging in this kind of empire building with ground military force.

So I think if you ask Cui Bono on 9/11, one of the big categories was all the people who made money on engineering the popular fear they needed to engineer these wars. I believe whether it was financial fraud, engineering new laws or engineering wars, it was a fantastically profitable covert operation. [45]

In that category of people who benefit from 9/11 are also the arms manufacturer Raytheon, whose share price gained directly from the 9/11 attacks. Trading of the shares of Raytheon, the producer of Tomahawk and Patriot missiles (and parent company of E-systems, whose clients include the National Security Agency and CIA), experienced an abrupt six-time increase of call option purchases on the day immediately before September 11. [46]

The outright purchase of call options implies the expectation that a stock price will rise. In the first week after 9/11, when the New York Stock Exchange opened again, the value of Raytheon actually shot up considerably. Looking at the development of the stock price, the impression is a very weak performance before the attacks - and then, after resumption of trade, a "gap" (at substantial volume) upwards. In other words: just under $25 on September 10, the low in the period between August 20 to September 28, at $31, 50 on September 17 and up to $34, and 80 on September 27, 2001.

With regards to government bonds, buyers of US Treasury securities with a maturity of five years were also winners. These securities were traded in an unusually large volume shortly before the attacks. The Wall Street Journal reported at least in early October 2001 that the Secret Service had started an investigation into a suspiciously high volume of US government bond purchases before the attacks. The Wall Street Journal explained:

Five-year Treasury bills are the best investments in the event of a global crisis, in particular one like this which has hit the United States. The papers are treasured because of their safety, and because they are covered by the US government, and usually their prices rise if investors shun riskier investments, such as shares. [47]

Adding to this phenomenon, the government issues these bonds that serve as a basis of money creation for funding a war such as the immediately declared "war on terror", engaging the Tomahawks from Raytheon. And here it may again be useful to have a quick look at the "cui bono" relationship:

The US Federal Reserve creates money to fund the war and lends it to the American government. The American government in turn must pay interest on the money they borrow from the Central Bank to fund the war. The greater the war appropriations, the greater the profits are for bankers. [48]

A multi-layered combination, one could say.

I also talked about the topic of 9/11 insider trading with one of the world's leading practitioners at the interface between the international capital markets, the national security policy of the US as well as geopolitics, James G Rickards. He gave me some answers in a personal discussion, which I am allowed to repeat here with his expressed approval.

Question: Did suspicious trading activities of uncovered put options on futures markets occur shortly before 9/11?

James G Rickards: Well, the trading documents certainly look suspicious. It is simply a fact that an unusually high volume of purchases of put-options for the two airlines occurred over the three trading days before the attacks. This is a mere fact, no speculation, no guessing around. This is clearly obvious from the documents of the trading sessions on the derivatives exchanges.

Question: Do you think that the intelligence agencies could have got a warning signal based on this information?

James G Rickards: Theoretically that is possible, if are you are looking and watching out for this. But there was far more significant information, which was ignored.

Question: Do you also think that some people with foreknowledge operated speculatively in the option markets?

James G Rickards: Based on the documentation of the trading session it seems that this has been the case, yes.

Let's sum up a bit at the end. We have, among other things:
 The "nice detective work" by Kevin Ryan related to Stratesec/Wirt Walker III. Some highly inconsistent information vis-a-vis Convar/illegal credit card transactions. Scientific papers supporting the allegations that there were indeed unusual trading activities in the option market before the terrorist attacks of 9/11, although the 9/11 Commission (based on the investigation of the SEC and the FBI) ruled that possibility out.

As it became clear that I would publish this article here at Asia Times Online, I contacted the US Federal Bureau of Investigation via its press spokesman Paul Bresson in order "to give the FBI the opportunity to give a public statement with regards to three specific issues". Those three specific issues were the ones I have just highlighted. Related to each of them I've asked Mr Bresson/the FBI: "Could you comment on this for the public, please?" Up to this moment, Mr Bresson/the FBI did not respond to my inquiry in any way whatsoever. Does this come as a surprise?

I've also got back in touch with "ars publicandi", the firm that does public relations for Convar in Germany. The response said: "Unfortunately I have to inform you that the status has not changed, and that Convar considers the issue of 9/11 as dead in general."

As you have read, the status in August of last year was slightly different.

At the end of this article, I should perhaps mention that this research ultimately led to negative consequences for me. After I contacted the FBI, I was informed by the publisher of a German financial website, for which I conducted interviews for a professional fee (and had already prepared more work), that no further cooperation was possible. Now that I will come in one way or another into the focus of the FBI, any association with me would be undesirable.

Well, you know the rules.

As far as the abnormal option trades around 9/11 are concerned, I want to give Max Keiser the last word in order to point out the significance of the story.

Max Keiser: Regardless of who did it, we can know that more than a few had advance warning - the trading in the option market makes that clear.

Notes
i. PROMIS was first developed by Inslaw during the 1970s under contracts and grants from the Law Enforcement Assistance Administration (LEAA). These guarantees gave the government licenses to use the early versions of PROMIS but not to modify them, or to create derivative works, or to distribute PROMIS outside the federal government. By 1982, because of strong disagreements over a fee-incentive, Modification 12 Agreement to the original contract, the United States Department of Justice and Inslaw Inc became involved in a widely-publicized and protracted lawsuit. PROMIS was originally designed as a case-management system for prosecutors. (Source Wikipedia.)
1. Compare Michael C Ruppert: Crossing the Rubicon: The Decline of the American Empire at the End of the Age Of Oil, New Society Publishers, Gabriola Island, 2004, page 152.
2. Ibid, page 153.
3. Ibid, page 154-155.
4. Ibid, page 170.
5. Ibid, page 238-253: "9/11 Insider Trading, or 'You Didn't Really See That, Even Though We Saw It'."
6. Ibid, page 239.
7. Compare Chris Blackhurst: "Mystery of terror 'insider dealers' ", published at The Independent on October 4, 2001, see here.
8. Compare "Profits of Death", published at From the Wilderness on December 6, 2001, see here.
9. For the fact, that it was George Tenet who recruited Krongard, compare George Tenet: At the Center of the Storm, Harper Collins, New York, 2007, page 19.
10. Compare Marc Chesney, Remo Crameri and Loriano Mancini: "Detecting Informed Trading Activities in the Option Markets", University of Zurich, April 2010, online here.
11. Nafeez M Ahmed: Geheimsache 09/11. Hintergründe uber den 11. September und die Logik amerikanischer Machtpolitik, Goldmann Verlag, Munich, 2004, page 182. (Translated back into English from German.)
12. Compare Michael C Ruppert: Crossing the Rubicon, page 244-247.
13. Wing-Keung Wong, Howard E. Thompson und Kweehong Teh: "Was there Abnormal Trading in the S&P 500 Index Options Prior to the September 11 Attacks?", published at Social Sciences Research Network, April 2010, see here.
14. Compare "Bank of America among 38 stocks in SEC's attack probe", published at Bloomberg News on October 3, 2001, archived here.
15. Michael C Ruppert: Crossing the Rubicon, page 243.
16. Ibid.
17. "Suppressed Details of Criminal Insider Trading Lead Directly into the CIA's Highest Ranks", published at From the Wilderness on October 9, 2001, see here.
18. Compare "Early September 2001: Almost Irrefutable Proof of Insider Trading in Germany", published at History Commons, see here.
19. Allen M Poteshman: "Unusual Option Market Activity and the Terrorist Attacks of September 11, 2001", published in The Journal of Business, University of Chicago Press, 2006, Vol 79, Edition 4, page 1703-1726.
20. Wing-Keung Wong, Howard E Thompson und Kweehong Teh: "Was there Abnormal Trading in the S&P 500 Index Options Prior to the September 11 Attacks?", see end note 13.
21. Ibid. The authors refer to Erin E Arvedlund: "Follow the money: terrorist conspirators could have profited more from fall of entire market than single stocks", published in Barron's on October 8, 2001.
22. Wong, Thompson, Teh: "Was there Abnormal Trading in the S&P 500 Index Options Prior to the September 11 Attacks?"
23. Ibid.
24. Ibid.
25. Marina Alcaraz: "11 septembre 2001: des volumes inhabituels sur les options peu avant l'attentat", published in Les Echos, page 34, September 10, 2001, online here.
26. Marc Chesney, Remo Crameri and Loriano Mancini: "Detecting Informed Trading Activities in the Option Markets", see end note 10.
27. Ibid.
28. ibid.
29. Ibid.
30. Compare Marc Chesney, Remo Crameri and Loriano Mancini: "Detecting Informed Trading Activities in the Option Markets", published at the University of Zurich on September 7, 2011, see here.
31. Vgl Lars Schall: "Sapere Aude!", German Interview with Dr Daniele Ganser, published at LarsSchall.com on August 18, 2011, see here.
32. Compare a copy of the letter by the SEC on MaxKeiser.com, see here.
33. Compare related to this agreement Matt Taibbi: "Is the SEC Covering Up Wall Street Crimes?", published at Rolling Stone on August 17, 2011, see here.
34. Mark H Gaffney: "Black 9/11: A Walk on the Dark Side", published at Foreign Policy Journal on March 2, 2011, see here.
35. Compare Peter Dale Scott: "Launching the US Terror War: the CIA, 9/11, Afghanistan, and Central Asia", The Asia-Pacific Journal, Vol 10, Issue 12, No 3, March 19, 2012, see online here.
35. Erik Kirschbaum: "German Firm Probes Last-Minute World Trade Center Transactions", published at Reuters on December 19, 2001, online here.
36. Ibid.
37. Ibid.
38. Michael C Ruppert: Crossing the Rubicon, page 244.
39. Ibid, page 423.
40. Ibid, page 423-426.
41. Commission Memorandum: "FBI Briefing on Trading", dated August 18, 2003, page 12, online here.
42. Lars Schall: "9/11 Was A Fantastically Profitable Covert Operation", Interview with Catherine Austin Fitts, published at LarsSchall.com on September 3, 2011, see here.
43. Ibid. Compare further related to the "cui bone" topic Catherine Austin Fitts: "9-11 Profiteering: A Framework for Building the 'Cui Bono'?", published at GlobalResearch on March 22, 2004, see here.
44. Lars Schall: "9/11 Was A Fantastically Profitable Covert Operation", see end note 42.
45. Compare "Bank of America among 38 stocks in SEC's attack probe", see end note 14. "A Raytheon option that makes money if shares are more than $25 each had 232 options contracts traded on the day before the attacks, almost six times the total number of trades that had occurred before that day. A contract represents options on 100 shares. Raytheon shares soared almost 37 percent to $34.04 during the first week of post-attack US trading."
46. Compare Barry Grey: "Suspicious trading points to advance knowledge by big investors of September 11 attacks," published at World Socialist Web Site on October 5, 2001, see here.
47. J S Kim: "Inside the Illusory Empire of the Banking Commodity Con Game," published at The Underground Investor on October 19, 2010, see here.

Lars Schall is a German financial journalist. This article is an exclusive, slightly modified and updated excerpt from the book Mordanschlag 9/11. Eine kriminalistische Recherche zu Finanzen, Ol und Drogen (Assassination 9/11: A criminalistic research on finance, oil and drugs), published in Germany by Schild Verlag.

Copyright 2012 Asia Times Online (Holdings) Ltd.

Rolling Stone, Matt Taibi (excerpts):
Did you hear about the plot to rig global interest rates? The $137 million fine for bilking needy schools and cities? The ingenious plan to suck multiple fees out of the unemployment checks of jobless workers? Take your eyes off them for 10 seconds and guaranteed, they'll be into some shit again - Bank of America has systematically ripped off almost everyone with whom it has a significant business relationship, cheating investors, insurers, depositors, homeowners, shareholders, pensioners and taxpayers. It brought tens of thousands of Americans to foreclosure court using bogus, "robo-signed" evidence – a type of mass perjury that it helped pioneer. It hawked worthless mortgages to dozens of unions and state pension funds, draining them of hundreds of millions in value.Last year, the Federal Reserve allowed Bank of America to move a huge portfolio of dangerous bets into a side of the company that happens to be FDIC-insured, putting all of us on the hook for as much as $55 trillion in irresponsible gambles. They lie, cheat and steal as reflexively as addicts, they laugh at people who are suffering and don't have money, they pay themselves huge salaries with money stolen from old people and taxpayers – and on top of it all, they completely suck at banking. And yet the state won't let them go out of business, no matter how much they deserve it, and it won't slap them in jail, no matter what crimes they commit. That makes them not bankers or capitalists, but a class of person that was never supposed to exist in America: royalty.Founded by a first-generation Italian-American named Amadeo Giannini – the bank set out to serve immigrants denied credit by other banks, and it was instrumental in helping to rebuild the city after the devastating earthquake of 1906. But like many of the truly bad ideas in history, the present-day version of Bank of America was the product of a testosterone overdose.. In the end, it all comes back to mortgages. Though Bank of America would ultimately be charged with committing a dizzyingly diverse variety of corporate misdeeds, the bulk of the trouble the bank is in today arises from the Great Mortgage Scam of the mid-2000s, which caused the biggest financial bubble in history.The holy trinity of Bank of America, Countrywide and Merrill Lynch represented the worst conceivable team of financial powers to get hold of this scam.In this case, it was the most careless mortgage lender ; the most dangerous mortgage gambler and the most relentless packager of mortgage pools. These guys were so corrupt, they even shocked one another: According to a federal lawsuit, top executives at Countrywide complained privately that Bank of America's "appetite for risky products was greater than that of Countrywide."
And what about that ostensible insurance that Bank of America sold with its bundles of mortgages? Well, those policies turned out not to be worth very much, since so many of the loans defaulted that they blew the insurers out of business. If you went bust buying bad mortgages from Bank of America, chances are, so did your insurer. At best, you two could now share a blanket in the poorhouse. Incredible as it sounds, owing practically everyone in the world billions of dollars apiece is only half of Bank of America's problem. The bank didn't just flee the scene of its various securities rip-offs. It also made a habit out of breaking the law and engaging in ethical lapses on a grand scale, all over the globe. Once your money ends up in their pockets, they just slither off into the night, no matter their legal or professional obligations. What's most striking in all of these scams is the corporate culture of Bank of America: These guys are just dicks. Time and again, they go out of their way to fleece their own customers, without a trace of remorse. In classic con-artist behavior, Bank of America even tried to rip off homeowners a second time by gaming President Obama's HAMP program, which was designed to aid families who had already been victimized by the banks. In a lawsuit filed last year, homeowners claim they were asked to submit a mountain of paperwork before receiving a modified loan – only to have the bank misplace the documents when it was time to pay up.The bank's list of victims goes on and on. The disabled? Just a few weeks ago, the government charged Bank of America with violating the Fair Housing Act by illegally requiring proof of disability from people who rely on disability income to make their mortgage payments. Minorities? Last December, the bank settled with the Justice Department for $335 million over Countrywide's practice of dumping risky subprime loans on qualified black and Hispanic borrowers. The poor? In South Carolina, Bank of America won a contract to distribute unemployment benefits through prepaid debit cards – and then charged multiple fees to jobless folk who had the gall to withdraw their money from anywhere other than a Bank of America ATM. Seriously, who hasn't this bank conspired to defraud? Puppies?
In sum, Bank of America torched dozens of institutional investors with billions in worthless loans, repeatedly refused to abide by contractual obligations to buy them back, evaded hundreds of millions in local fees and taxes, pushed tens of thousands of people into foreclosure using phony documents, ignored multiple court orders to stop its illegal robo-signing, and exploited President Obama's signature mortgage-relief program. The bank fixed the bids on bonds for schools and cities and utilities all over America, and even conspired to try to game the game itself – by fixing global interest rates! Bank of America should have gone out of business back in 2008. Just as the mortgage market was crashing, it made an inconceivably stupid investment in subprime mortgages, acquiring Countrywide and the billions in potential lawsuits that came with it. "They tried to catch a falling knife and lost their hand and foot in the process," says Joshua Rosner, a noted financial analyst. It then spent $50 billion buying a firm, Merrill Lynch, that was rife with billions in debts. With those two anchors on its balance sheet, Hugh McColl's bicoastal dream bank should have gone the way of the dinosaur.But it didn't. Instead, in the midst of the crash, the government forked over $45 billion in aid to Bank of America – $20 billion as an incentive to bring its cross-eyed bride Merrill Lynch to the altar, and another $25 billion as part of the overall TARP bailout. In addition, the government agreed to guarantee $118 billion in Bank of America debt. But by far the biggest bailout to Bank of America has come via the sweetheart deals it cut to settle the massive lawsuits filed against it. Some of the deals, which were brokered by the Justice Department and state attorneys general, allowed the bank to get away with paying pennies on the dollar on its mountains of debt. Worst of all was the recent $26 billion foreclosure settlement involving Bank of America and four other major firms. The deal, in which the banks agreed to pay cash to screwed-over homeowners in exchange for immunity from federal prosecution on robo-signing issues, was hailed as a big multibillion-dollar bite out of the banks. President Obama was all but strutting over his beatdown of Wall Street. "We are Americans, and we look out for one another; we get each other's backs," he declared. "We're going to make sure that banks live up to their end of the bargain."
Oh, and one more thing, since we're talking about avoiding bills: Bank of America didn't pay a dime in federal taxes last year. Or the year before. And here's the biggest scam of all: After all that help – all the billions in bailouts, the tens of billions in Fed loans, the hundreds of billions in legal damages made to disappear, the untold billions more of unpaid bills and buybacks – Bank of America is still failing. In December, the bank's share price dipped below $5, and after being cut off by Fannie in February, the bank announced a truly shameless plan to jack up fees for depositors by as much as $25 a month .
The Dodd-Frank financial reform approved by Congress last year was supposed to fix the problem of Too Big to Fail, giving the government the power to take over and disband troubled megafirms instead of bailing them out. "The way to cut our Gordian financial knot is simple," MIT economist Simon Johnson wrote in The New York Times. "Force the big banks to become smaller." But few in the financial community believe that will ever happen. "If Bank of America crashes, the first thing that would happen is Dodd-Frank would be revealed as a fraud," says Rosner. "The Fed and the Treasury would ask Congress for a bailout to 'save the economy.' It's the worst-kept secret on Wall Street."In a pure capitalist system, an institution as moronic and corrupt as Bank of America would be swiftly punished by the market – the executives would get to loot their own firms once, then they'd be looking for jobs again. But with the limitless government support of Too Big to Fail, these failing financial giants get to stay undead forever, continually looting the taxpayer, their depositors, their shareholders and anyone else they can get their hands on. The threat posed by Bank of America isn't just financial – it's a full-blown assault on the American dream.

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