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Forest
Fire
(Originally Issued
January 1, 2001)
This Commentary was taken from notes for a talk at the National Bureau of
Economic Research’s December 8, 2000 meeting of its Market Microstructure Group.
I argue that a bias may exist in microstructure (and other) research in favor of
conclusions that support regulatory intervention. Since this piece is longer
than usual, I present the main argument in the first 4 pages, followed by two
addenda. The first addendum suggests research topics that may elucidate the
flaws in current market structure theory. The second explores bias in the field
of medical research to demonstrate that the tendency in favor of intervention is
not confined to the stock market.
Knowing how I like to wander onto unexpected topics in search
of perspective, Bruce1
said I could talk about anything today – but also suggested I might say
something particular about the tendency of research to focus only on what we can
observe and measure. So I’ll both wander and try to keep focused on the
old missing-the-forest-for-the-trees problem. You know: the age-old phenomenon
of missing the big picture while looking in excruciating detail at the minutiae.
Do researchers and scientists make this mistake because they like looking
only at the little things? Or is it because they don’t have the tools yet to
look beyond them? Either or both of these could explain at least some of the
phenomenon. But I wonder if there couldn’t also be a subconscious bias in the
selection of subjects to look into, or a subtle slant on interpretation.
Bluntly, are researchers not just “missing” the forest, but actually avoiding
it? Are they looking so intently at the trees as a means of avoiding the
implications lurking in the forest? If so, what is their motive? Taking a page
from Christie-Schultz,2
I’ll ask you to consider if there isn’t a dog that didn’t bark here, too.
Just as the lack of odd-eighths pointed to tacit collusion among dealers to
maintain wide spreads, are researchers avoiding the forest pursuant to a tacit
understanding with regulators to avoid conclusions that would undermine the case
for intervention? Just as dealers had a career interest in wide spreads, don’t
academics and bureaucrats share a career interest in redesigning the markets?
Microstructure, perhaps surprisingly, was not the first place
I noticed the pattern. In fact, it seems to apply in virtually all major fields
of modern human endeavor. In one after another, you will find well-intended
interventions based on the best academic and scientific advice, their obvious
failure (to laymen, anyway), ostracism of those who flag the failure, and
official cover-ups. At every step along the way, there is an uncanny tendency to
ignore the big picture. The party line becomes: Even if we did make mistakes,
it will do no good to call attention to them now, because that will only
undermine support for the good things we are going to do next. In the field
of medicine, for example, vaccines – in addition to whatever benefits they have
produced – are also alleged to have produced some major disasters. But rather
than checking out the charges, health officials often issue facile denials,
while cautioning against repeating the charges for fear that doing so will spark
an unwillingness to submit to further vaccinations. Surprisingly, at least to
those of us who assume that research is generally honest, dispassionate and
unbiased, most researchers seem to buy into and support the cover-up – and twist
their research to that end.3
Hypocritic Oaths
Moving back closer to home, some of you know that I have been
critical of the SEC’s National Market System.4
If you’ve followed my NMS gripes, you probably also know that I was at first
perplexed by NMS’s consistency with antitrust. I was perplexed because I had
previously assumed, as had other NMS critics, that those who wrote NMS into the
Exchange Act must have somehow misinterpreted antitrust. But the more I looked,
the more I saw that NMS was in fact an essentially correct expression of
competition policy. So either I was wrong about NMS, or antitrust had to go,
too. I considered the former for a few minutes, and then went on to figuring out
what was wrong with antitrust.
When I began looking into antitrust a decade ago, I was reading, and often
cutting out and saving, an article or two a week from newspapers and magazines
(my favorite mode of research). Today the same criteria produce a dozen or more
per day. Early on I noticed that a strange quote from Adam Smith kept popping
up. Even though I had never read Wealth of Nations, I knew – or thought I
did – that Smith was one of the good guys. His “invisible hand” had inspired
anti-Government ideologues like me since before the American experiment in
freedom and limited Government began. So I was confused when most of the
references to Smith involved a quote, not about the invisible hand or any such
free market stuff, but about how (and I paraphrase) businessmen can’t even go
on a picnic without colluding to fix prices. So I faced a conundrum: either
I had misunderstood Adam Smith entirely, and he actually was the father of
antitrust, or the economists who were always quoting him to that effect had
misunderstood him. So I broke from my usual style and got a copy of Wealth of
Nations – and I bet I am the only person you know who read that whole book
just to find out what he said next. I won’t keep you in suspense (and again I
paraphrase): So prevalent is collusion, that it is impossible for Government
to stop it and any attempts to do so will be inconsistent with liberty and
justice. And, while you can’t stop collusion and shouldn’t try to, you shouldn’t
do anything to officially facilitate it, either.5
Actually, it’s not quite correct to say that the references to Smith didn’t
include the invisible hand. They usually mentioned it along with the collusion
quote to imply that even Adam Smith, he of invisible hand fame, understood the
need for Government intervention to enforce antitrust-style competition policy.
In other words, they referenced the invisible hand as a means of discrediting
the entire concept – and invoked Adam Smith himself to do so.6
Well, with all due respect, not only have such people apparently forgotten the
two sentences after their favorite quote, but they’ve forgotten the rest of the
book, too. There is no way to read the few references to collusion – including
the trustbusters’ favorite – as supportive of antitrust. And every word of the
rest of the book is devoted to warning against just such interventions. The
Justice Department is doing exactly what Smith said is impossible and
inconsistent with justice (how’s that for irony). And, via the rent-seeking
frenzies in regulated industries administered by the courts and the alphabet
soup of antitrust agencies, our Government is officially facilitating precisely
those gatherings Smith warned against. Relieved as I was to find that Adam Smith
is still one of the good guys, this first experience with the dog that didn’t
bark told me that preserving his principles was going to be much harder than I
thought.
My next experience with this non-barking dog is amusing. I learned from a good
friend named Lew Randall, a guy who had taken economics courses as an
undergraduate at Harvard and a grad student at Stanford, that Adam Smith has
many successors in the libertarian tradition. They’re called “Austrians” –
people like Mises, Hayek, Rothbard and Armentano. The funny thing is that none
of them were mentioned during Lew’s academic career at those prestigious
universities. It wasn’t until afterward that he stumbled on the Austrian School
and found to his surprise that “economics does make sense after all.” Later
asking one of his former professors if they (the economics faculty) knew about
the Austrians, he said sure they did – but they didn’t teach them. No
wonder academic research is biased toward intervention.
An example of this bias can be seen in the argument over “deregulation.” Thirty
years ago Richard Posner wrote a book suggesting that “natural monopolies” like
electric utilities should be deregulated and henceforth subject “only” to the
antitrust laws.7
While the book made powerful arguments against utility-style monopoly
regulation, the largely tacit assumption was that the only alternative was
antitrust regulation. Thus, in keeping with the twisted understanding of Adam
Smith, and the failure to acknowledge the Austrian School, the economic
establishment gives us only two choices: utility regulation of monopolies, or
deregulation and breakup of those monopolies under antitrust. The first is
presented as the Government solution; the latter as the free market solution.
This sets up what I call The Big Toggle. With supposedly free market types
arguing for deregulation and supposedly socialist types arguing against it,
public and political support swings back and forth from regulation to
deregulation to re-regulation. It is implicitly assumed by the very existence of
the Big Toggle argument that the Austrian option does not exist. How could
research not favor intervention, when the philosophical argument over
regulation is confined to two essentially socialist positions – with antitrust
on the right?
Never mind my own view that we’d be better off with
unfettered private monopolies running such network industries as electric
utilities, telecommunications, airlines, and oil. And forget that these Big
Toggle industries are the ones that are most in the news for their repeated
crises, dislocations, price controls, rationing, shortages, Congressional
hearings and consumer rage. Just focus on two things: 1) Every move from one
node to the other of the Big Toggle produces immediate unintended
consequences and stunned surprise among the experts (California blackout
threats and price spikes are the best current example). 2) In spite of their
obvious cluelessness, the experts never consider that the problem might be
with their Big Toggle model. Taken together, these two facts leave little
room for any other conclusion than that some tacit understanding must exist
among the experts to avoid research that might undermine the case for
intervention. While often swearing allegiance to the opening admonition of the
Hippocratic Oath – First, Do No Harm8
– the experts demonstrate over and over that their real allegiance is to
intervention.
The Role of Regulation and the Evolution of Market Design
The biggest dog-that-didn’t-bark of all is typified in the
above heading, which I took from the “Call for Papers” for this meeting.
Bluntly, regulation has nothing to do with the evolution of market design; to
imply otherwise by putting them in the same sentence implies a complete
misunderstanding of the nature of evolution. As with Adam Smith, Darwin’s Theory
of Evolution has been turned upside down to justify all kinds of man-made
intrusions into the natural order of things. Darwin did not invent the term
“evolution,” nor the term “selection.” His unique and grand contribution was to
take the concept of selection, as practiced by breeders of sheep, dogs and
pigeons, to demonstrate that Natural Selection could produce the most
efficiently adapted species. Through variation, competition and survival of the
fittest, he hypothesized, all the earth’s complex and beautiful creatures could
have evolved. Dog breeders and pigeon fanciers were only examples to
explain how selection could modify species. Darwin never suggested that your
prize poodle could survive among wolves in the wild. Yet no sooner had he
articulated his theory, than his cousin Sir Francis Galton, of all people,
founded the eugenics movement. Although always projected as an expression of
Darwinian principles, eugenics is in fact the opposite, a throwback to plain old
selection that invokes Darwin’s name to justify all manner of interventionist
schemes. Some were benign enough; some were outright evil. No one would argue
with someone trying to breed a best-in-show dog in his own kennel. Most would
draw the line at trying to create a master race. Evil or benign, what all
eugenic exercises share is a thoroughly un-Darwinian attachment to
intervention.
Darwin was most poetic in his descriptions of how man could
feel sympathy for his fellows. This enabled such winning traits as cooperation,
of which hunting in packs was an early manifestation in animals and man.
Eventually, of course, man rose above the animals by moving on to more
sophisticated forms of cooperation, like gathering, farming, and industry. So it
is not surprising that, when the antitrust investigations triggered by
Christie-Schultz discovered that Nasdaq dealers were still hunting in packs, the
immediate impulse was to ban the practice. It seemed an easy call. Dealers were
indeed maneuvering to make more money off their customers by using all of the
information and access advantages that came with membership in their market. And
– horror of horrors – they were cooperating to set block and IPO prices,
not to mention colluding to avoid those mysteriously missing odd-eighths.
But there was nothing “tacit” about it. If the good professors had only asked
any dealer why there were no odd eighths, he would have told them: “Oh that’s
easy – we trade in quarters.” As with all the other dastardly practices the
aghast regulators found, dealers were relatively open to discussing why adhering
to them was part of how any “professional” and “ethical” dealer behaved. New
recruits were specifically taught these habits, and much of it was routinely
captured on recorded phone lines. Obviously, they didn’t feel as guilty as the
regulators felt they should. Why? They knew they were only doing their own
version of what stock exchange members have always done. Indeed, given the
success of the Nasdaq market prior to the time the regulators got ahold of it,
the real question, the one Darwin – a more humble man than any of today’s
regulators – would be asking is: Why is it that this new version of hunting in
packs is so effective at raising capital?
The natural order is not a level playing field. The very
concept of order assumes hierarchical forms of organization. There will always
be many mysterious arrangements and structures, from hunting in packs to pecking
orders, the “purpose” of which, in an evolutionary sense, will always be beyond
the capacity of mere mortals to know. Who’s to say, for example, what roles the
“unfair” allocation process for IPOs, or upstairs dealer cooperation on their
pricing, may have played as part of an efficient capital raising process? The
assumption that regulators can eugenically substitute mere selection for
natural selection without unintended disasters is the essence of hubris.
Did the ban on pricing cooperation encourage the rocketship IPO? Did rocketship
IPOs promote the tech stock bubble? The fact that we may never know the answers
to such questions is not a sufficient excuse to abandon the natural processes
that Adam Smith and Charles Darwin believed are essential for the development of
efficient structures.
It is ironic beyond imagining that cooperation, the very trait that Darwin
considered most responsible for man’s success in evolutionary competition, is
that which is most assiduously banned by interventionist regulators. And it
positively insults the intelligence that they invoke Darwin to justify their
interventions. But the question I want to ask you – the research community – is
why do you let them get away with it? A new survey shows that you are more
inclined to see intervention as beneficial than either institutional investors
or dealers.9
Why? I understand the incentives of regulators to intervene. I understand the
political appeal of “fairness.” But why in the world are you providing
cover for interventionist schemes with political agendas? What
academic theory suggests that level playing fields are efficient?
The net effect of the endless stream of studies on spreads is
to give the impression that getting rid of them – and the dealers who earn them
– is a good idea. Not surprisingly, getting dealers out of the middle whenever
possible is an explicit goal of NMS. This obviously requires massive
intervention, employs many bureaucrats, and confers credibility on the academics
whose studies justify the reforms. Missing the forest for the trees, researchers
scrutinize the details of declining trading costs ad infinitum without ever
asking the big question: So What? To my knowledge, none of the critical implicit
assumptions of the National Market System have even been rigorously identified,
much less tested and proved. Transparency, automation, trading without dealers,
decimalization, demutualization, linkage, best execution, and many more are all
treated as aspects of the market that can be improved, feature by feature,
mandate by mandate. The blithe assumption that all of the market’s original,
naturally evolved features can be replaced one by one without unintended
consequences, and that doing this is so important that an essentially socialist
process for designing and mandating the changes is justified, defies
comprehension – at least by this free market ideologue. The question I would ask
you to consider is what role academic research plays in this process. Is there
identifiable bias in the selection of research topics or in the interpretation
of results? If so, why?
First Addendum
The
Challenge:
The National Market System (NMS) relies on many assumptions
that have never been tested, much less proved. Transparency, for example, is
assumed to be beneficial, as are automation, trading without dealers, linkage
between markets, best execution, price improvement, and decimalization, to name
just a few. Not only are they not proved individually, but each of them is often
justified in circular fashion by claiming the need to enhance the operation of
one or more of the others. The assumed need for transparency is used to justify
decimalization, for example. And all of them, singly and en masse, are regularly
used to justify the NMS intervention, itself – and vice versa. None of them,
including the term “national market system,” are defined in the law or, for
practical purposes, anywhere else.
Once the core concepts are assumed to be true, the way is
open for a boatload of ancillary concepts to take on similar forgone conclusion
status by cross-referencing the core concepts. Since trading without dealers is
good, automation must be good. Since automation is good, anonymity must be, too.
Since the automated systems that provide anonymity are good, but dealers
wouldn’t willingly accept them, forcing dealers to accept them with an NMS
bureaucracy must be good. Since forcing dealers to accept such anathema features
as automation, transparency, and anonymity is good, then seeing them abandon
their membership organizations via demutualization must be good, too.
Once all these cross-referenced forgone conclusions are
locked in to everyone’s minds, it even becomes possible to tell the good guys
from the bad guys. Dealers are bad guys, because they oppose all the “good” NMS
features that disintermediate them. Regulators, academics and the little guy –
on whose behalf they fight for automation, transparency, and anonymity – are the
good guys. Knowing who the good guys and bad guys are encourages essentially
political calls to be made regarding the efficacy of market structure features.
Because the good guys want decimals, and the bad guys don’t, decimals must
really be good. Because the bad guys don’t want competition from the likes of
SOES Bandits, individuals, or ECNs, the more such competition the better.
Because the good guys want 24-hour trading and the bad guys don’t, 24-hour
trading must be good. And so it is that the assumed efficacy of such features as
decimalization, fragmenting competition, and 24-hour trading becomes further set
in theoretical stone because of their political popularity.
The net effect of all the non-defined terms,
cross-referential validations, unproved assumptions, and political judgements is
that, structurally, the whole NMS edifice lies some-where between a hall of
mirrors and a house of cards. If any one assumption can be successfully
challenged, NMS might just fade away like a bad dream. With that hope in mind,
below are some suggestions of where investigations may prove fruitful in
challenging NMS. Each successfully challenged feature, by itself, could lead to
bene-ficial course corrections. However, by keeping NMS in mind while testing
its features one by one, the root cause of all the problems may, in the end,
become clear. That problem is Hubris: the always-unwise willingness to overturn
the structures and features created naturally through innovation, competition
and survival of the fittest. While the interventionists often seek to call their
process “evolution,” as if they were merely aiding an inevitable adjustment to
changing conditions or technology, Darwin would have rejected that claim.
Redesigning the stock market through regulation is far closer to the perversion
of his Theory of Evolution known as eugenics.
Suggested Investigations:
Question Transparency
Sometimes called the motherhood and apple pie of U.S. stock
market regulation, transparency is assumed to be beneficial. Few academics have
questioned this, with the notable recent exception of a paper by Madhavan,
Porter and Weaver, which shows that a switch from a non-transparent to a
transparent system in Canada was harmful on several counts.10
Hopefully, other countries will offer their markets as guinea pigs too, since it
is unlikely, judging by the paper’s reception at the SEC so far, that even a
clear piece of empirical evidence such as this will, by itself, bring about a
reconsideration of transparency policy. In the meantime, researchers might try
looking in the following unusual places for evidence that might falsify the
transparency hypothesis. Even if you don’t succeed, the mere act of looking
could itself have the beneficial effect of moving the issue back to hypothesis
status.
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· Try looking into the difference between how
transparency plays out in a call market rather than in continuous trading.
I believe you will find that, while transparency can make a good deal of
sense in a call market, it is bad strategy and bad policy in continuous
trading.11
A useful analogy may be available in election reporting practices, as seen
vividly recently. The ban on reporting election returns or exit polls
before voting is over stems from a general sense that continuous
transparency is unfair. Did voters in Oregon or California – or the
Florida Panhandle – stay home after the TV networks began calling the
election for Gore before their polls closed? If unfair, for whom? The
individual who didn’t vote because it seemed over? The state whose outcome
and commitment of electors to the Electoral College his vote could have
affected? Or the country as a whole?
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· Apart from the fairness issue, what feedback
effects might distort results if continuous reporting of election returns
or exit polls, such as could be shown on an election “tape,” showed
momentum for one candidate or the other? If continuous reporting were
allowed, what potential for manipulation and dirty tricks would become
available? Wouldn’t the effect of push polling be magnified with election
transparency? What is the stock market equivalent of such fraudulent
manipulation, and how does continuous transparency enable it? If bubbles
began with newspapers, as Shiller suggests in Irrational Exuberance,12
what effect would continuous wireless access to continuously moving prices
and trading have?
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What similarities are there between discovering the will of the people in
a democracy through voting, and discovering the correct price of a stock
through trading in a market? How important is the method used for casting
votes and tallying the results, or for discovering the price?
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Extra Credit: There are many who support transparency in election
reporting, including some of the news stations and other First Amendment
advocates. Some of these are presumably not merely self-interested, but
have arguably valid theoretical, historical or legal cases to make. Is
there a conflict between the First Amendment and getting correct results
in a fair election that reflects the true will of the people? Even if
continuous election reporting would be a disaster in terms of fairness of
process and correctness of results, does the First Amendment require it,
anyway? If so, what kind of legislative or Constitutional changes might be
necessary to restore true democracy? |
Although the situations are clearly different in some
important respects, I suspect the lessons learned in a systematic evaluation of
whether transparency makes sense in election reporting will have much to say
about the wisdom of transparency in stock trading. Just as waiting to report
election returns until after all the votes are in – i.e., as in a call market –
will be shown to make sense, continuous transparency in the stock market will be
shown to be foolish. It is bound to create distortions, enhance volatility, harm
liquidity, generate a sense of unfairness, and encourage fraudulent
manipulation. Furthermore, because every buy-side trader and every sell-side
trader knows that transparency is unwise strategy, the only way to force it
through as policy is with an intrusive bureaucracy that violates our idea of a
free market.
Question the Efficient Market Hypothesis
Maybe it was Walras who got the EMH thing started. I
understand he was the 19th century economist who used the call market then at
the Paris Bourse as a heuristic to describe how supply and demand crossed at an
efficient price. Since then, it appears that all markets have been assumed to
efficiently discover price as if they were calls – although almost none of them
are any more. Most references to calls in the standard taxonomies treat them as
of no more structural significance than what language the locals speak or what
currency their trades are denominated in. Any functional advantages or
disadvantages calls may have relative to the continuous alternatives seem merely
“operational,” having no bearing on whether the price discovered is correct. EMH
is, in this view, an immutable Law of Nature. Because the price is always right,
regardless of structure, regulatory intervention can be safely undertaken. No
need to worry about price discovery or capital formation. EMH plus the Law of
One Price (arbitrage) will take care of such things.
Such assumptions lead regulators, Congress and academics to
experiment freely with new market structures to incorporate politically popular
fairness features. Their deeply held belief in the Efficient Market Hypothesis
gives them confidence that any structural flaws introduced are of no real
consequence in terms of efficiency. Apparent evidence of bubbles or other
aberrations can be attributed to the irrationality of investors, rather than to
any malfunction of the market’s trading mechanism. This view gives
interventionists carte blanche to monkey with the structure in order to
accomplish such politically popular goals as increment narrowing or other forms
of “democratization” that help the little guy at the expense of the big guy
(institutions and dealers). Whether a call market or a continuous market,
whether a market of infrequent and giant upstairs blocks, or one of anonymous
machines spewing multiple tiny prints per second – nothing can go wrong can go
wrong can go wrong can go wrong.
But, just in case there is a connection between the efficiency of the market
price as discovered and the efficiency of the mechanism that produces it,
researchers could explore the implications by asking some of the following
questions.
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· What if the market price could diverge
significantly and for long periods from efficiency? Consider how the
traditional functions of liquidity, price discovery, capital raising etc.
would work if the market really were a casino, with prices coming
from some subterranean roulette wheel, while the analysts, investors and
reporters tried to make sense of it all. Would that encourage IPOs of lots
of phony companies? Would it place a premium on hype over value? (Just
thinking hypothetically, of course.)
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· The paper offered at this meeting by Chordia,
Roll, and Subrahmanyam, "Market Liquidity and Trading Activity," shows
liquidity changing over time, and some unsuspected price effects from
those changes. If liquidity matters to price, and can change over time, is
it possible that market structure matters, too, since it conceivably might
affect liquidity? It may, at least, matter in the traditional sense that
liquid assets are more valuable than illiquid ones. But what if the
accuracy of price discovery could come unglued in sufficiently illiquid
conditions, such as when markets “melt down” or “seize up”? EMH assumes
that such incorrectness is either nonexistent or very temporary. It seems,
though, that if liquidity affects price, then market structure may, too.
If so, need these effects be confined to the occasional brief meltdown?
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· Develop a model for the relationship between
liquidity demands and price discovery. How would the strength of liquidity
demands affect the robustness of the discovered price? How would
variations in robustness of the discovered price affect the ability to
express liquidity demands to the market? Does EMH always operate, or would
it take a “fast market” break during a meltdown?
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· How would NMS principles affect or be
affected by one market type or the other? How would transparency work in a
call versus a continuous setting? Decimals? Linkage? Automation?
Demutualization? Would the strength of EMH be affected by any answers to
such questions, and could it vary from structure to structure?
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· What different types of calls are there, and
how would those NMS features work in each of them? Would differences
affect the robustness of EMH?
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· What would the effect of different degrees
and types of continuousness be on the NMS features and on the efficiency
of price formation? How would transparency be enhanced or harmed, for
example, by a stock that trades 1,000,000 shares in 1,000 trades of 1,000
shares each, versus 10,000 trades of 100 shares each? Could the
difference, if any, affect the strength of EMH? Which is more transparent? |
Check Out Game Theory
The practices of stock markets evolved naturally for
centuries without Government help. Perhaps for that reason, Government seems
bent on attacking each and every settled arrangement or understanding by which
trading had proceeded. From information creation, control and dissemination to
tick sizes and compensation policies; from payment for order flow to soft
dollars; from the hierarchically arranged block trading system, in which size
talked to size, to the non-anonymous party-to-party dealing that supported it;
from the information and access advantages of exchange members to their special
relationships with the institutions they served – all of the these and many more
are targeted for mandatory “change.” In spite of their confident willingness to
radically alter the structure, regulators seem blissfully unaware of the subtle
value of interpersonal, reputation-based arrangements that encouraged its
creation and maintenance. They cannot be expected, therefore, to carry over any
of them to the new regime.
Some of the old practices can be modeled with various Game
Theory concepts, which describe the often implicit and hidden protocols by which
cooperation among parties develops and is maintained. While antitrust regulators
may consider many forms of cooperation evil, Darwin himself recognized the
central importance of sympathy, which provides the instinctive basis for the
cooperation that supports all the social, religious and business institutions
that enabled man to rise above the animals. Because Game Theory is both so
relevant to the world of trading that is being mandated away, and so clearly not
part of any of the theoretical discussions that led to the mandates, there are
few more fertile fields for planting seeds of doubt in NMS theories.
For example, researchers were at first surprised to find
examples of “irrational” altruism in Prisoner’s Dilemma games with monetary
rewards. Subjects even seek to cooperate with other players they do not know,
and will never know (nor will the other players know them) in a one shot game,
even though they could make more money personally by defecting (not
cooperating). Although a tit-for-tat reciprocation strategy usually works best,
whether the other player’s opening move is cooperation or defection, the first
move, more often than not, is cooperation. While some Chicago economists may
find this perplexing, Darwin would probably not have been surprised to hear that
the cooperation gene is hardwired into us all. In any case, researchers have
also discovered that the more the players know each other, and the longer the
games are played, the more cooperation becomes the default strategy. This is
because, in a non-anonymous environment, cheaters can be punished and
cooperators rewarded.13
Another fruitful area of inquiry involves the Winner’s Curse,
in which a winning bidder pays more than an asset is worth. The literature seems
to focus on the seemingly mysterious phenomenon of how bidding excitement pushes
winning bidders to overpay relative to the eventually achievable value of an
asset, such as a right to drill for oil.14
A more interesting phenomenon in the market structure context is the special
case of what you might call a built-in Winner’s Curse. Here the trading
structure is designed – either accidentally or deliberately – such that it is
likely to produce immediate regret, because others can get better prices at the
same time. Even if this is only a theoretical possibility, its existence places
an uncomfortable strategy burden on bidders that can make them shrink from
participation.
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· Anonymity is one of the assumed benefits of
electronic trading. This glib assumption implicitly dismisses any benefit
from non-anonymous trading, such as characterized block dealing and floor
trading. In this old reputation-based liquidity and price discovery
network, dishonest players (i.e., cheaters in a Prisoner’s Dilemma
context) risked ostracism, which effectively meted out severe financial
and career penalties to them. Robust price discovery was a likely
consequence of this size-adjudicating cooperation enforced by classic
tit-for-tat behavior. Can the old methods, which seemingly encouraged
honest, confidential disclosure of market-moving size, be modeled? If all
market-moving size were handled this way, would this not constitute a
complete network-wide picture of supply and demand, and, thus, lead to an
efficient price? Can the dangers of anonymous electronic trading, which
discourage the honest disclosure of market-moving size to anyone, be
demonstrated?
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· SEC and Justice Department investigators were
appalled at the brazenness of Nasdaq dealers’ admissions of collusive
behavior to enforce fat increments and spreads. They were particularly
amazed at the fact that they seemed openly proud of the means by which
they enforced cooperation and punished cheaters who broke the spread.
Clearly proud of their success at this Prisoner’s Dilemma game called The
Dealer Market, and its role in capital formation, dealers described their
activities openly to investigators. And they engaged in these evil
practices (according to the investigators’ assumptions) without apparent
guilt on recorded phone lines. They even considered it “unprofessional”
and “unethical” not to adhere to their practices, and took particular care
to educate new recruits in the importance of being professional and
ethical – which really threw the antitrust team for a loop. The dealers
obviously didn’t think they had done anything wrong, and believed
fervently in the value of their “collusive” activities to society. I do
too. In fact, if the model of a robust, reputation-based price discovery
network suggested above holds, the similar network created by the Nasdaq
dealers’ behavior will fit right in.
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· While the Nasdaq regulators’ investigations
afforded an unusual opportunity to peer into the mechanisms and hidden
incentives behind the practices of this one market, it is likely that all
the other markets since time immemorial have exhibited similar behavior.
Would a comprehensive historical review of the formation of exchanges
demonstrate this? The term “Prisoner’s Dilemma” sounds unappealing –
obviously nobody wants to be a prisoner. But the fact is that the rewards
from successful play in the stock exchange version of this game are
clearly great. Can a model of the nature and power of these rewards be
developed? What role did the lure of such rewards play in encouraging
exchanges to form? If regulators ban the game – or at least the rewards
that made it worth playing – what will happen to exchange formation? Can
proprietary ECNs do any of the reputation-based heavy lifting in the price
discovery and liquidity categories? I suspect not. If not, is there any
model anywhere that can demonstrate why it is a good idea to throw out the
old exchanges before we have any idea what the new ones can do?
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· The “name your own price,” or limit order,
systems of Priceline and Optimark both suffered when users perceived they
could get bad prices relative to other users at the same time. This is a
built-in Winner’s Curse. Priceline’s patented “reverse auction,” a “demand
collection system,” was designed to allow (encourage?) uninformed people
to overbid, and not even Captain Kirk himself could keep them coming once
they figured that out. Similarly, Optimark’s patented “multi-price
auction” prompted much hesitancy among participants, once they figured it
out, although that took them awhile; even those who attended the “Optimark
Institute” training programs were seldom aware of the problem upon
graduation. Apparently, naming their own limits did not stop users from
dropping out of either system and, in the case of Priceline, filing
lawsuits alleging misrepresentation. There may be more similarity than
difference between these systems and continuous electronic trading
systems, especially now that they have moved into a “sub-second”
environment. While, technically, “best execution” rules prevent a Winner’s
Curse problem at any point in time, the fact is that there may be many
better prices received at or in close proximity to the time of your trade.
Can a Winner’s Curse model be developed that explains the problems with
Priceline and Optimark? Is there any reason to think consumer satisfaction
with, say, SuperMontage or a CLOB will be any better than those failed
systems? In particular, would naming their own price with limit orders,
which regulators are encouraging due to increased volatility, lead to any
greater investor satisfaction in SuperMontage than it did in Priceline or
Optimark? One difference between them, of course, is that Priceline and
Optimark were private initiatives and merely cost their backers a few
hundred million or a few billion dollars when they failed, whereas
SuperMontage and CLOB would be, in effect, mandatory monopolies decreed by
regulators. What would have happened if regulators had mandated Priceline
for purchasing all airline tickets? Or Optimark for all stock trading? |
Question Antitrust and Demutualization
Prevented from engaging in most of their traditional
cooperation-enforcement mechanisms, exchanges have lost their raison d’être.
Thus, regulatory pressure is the real reason exchanges are demutualizing. It is
not, as is frequently alleged by regulators and their supporters, the need to
streamline governance, issue stock to finance trading systems, get rid of
political obstacles to automation, or any of the other convenient smokescreens.
Of course, the exchanges’ members are opposed to those disintermediating
enhancements. It was partly to be able to circle the wagons against such threats
that memberships were formed in the first place. And of course, if they are not
allowed anymore to do what membership exchanges used to do, they will certainly
move quickly to proprietary business models. But regulators are the cause of the
shift in strategy. Rather than simply allowing new competitors to innovate
around the old markets, the basic thrust of regulation is now to force the old
ones to change. That is why it is essentially correct to say that the primary
reason to demututalize is regulatory pressure. Demutualizing to get rid of the
political objections to innovation is simply not an idea bubbling up from the
members; it is being forced down their throats by regulators who have left them
no choice.
It is important to recognize that demutualization is an
intended – or at least inevitable – consequence of regulatory reform. This
recognition is important in order to prevent interventionist regulators from
being able to shirk their responsibility for causing demutualization, as if it
were only in response to exogenous changes in the competitive or technological
landscape. Although such claims are made regularly by regulators, and all too
often by their academic supporters, the truth should not be allowed to escape.
It is only by remembering that these reforms are man-made that we can
avoid the further interventionist takeover by regulatory bureaucracies when they
fail. If we forget, then, when demutualization proves disastrous, as I expect it
will, the line out of Washington will be: In view of perceived problems
accompanying certain restructuring plans of some exchanges, new regulatory
authority to oversee certain critical market functions is necessary.
It is interesting that, as recently as the 1997 “order
handling” reforms that grew out of the successful antitrust investigations,
regulators were positively boastful that they were able to push through such
radical changes. While recognizing how controversial they were, they pointed out
that the one thing their supporters and detractors agreed on was that they would
result in radical change. Regulators not only agreed, but confidently proclaimed
that radical change was their intent. Well, now that we have had day
trading, volatility, a drastic separation of growth from value stocks (which
began, by the way, with the order handling rules), an explosion of fraud, the
collapse of the dot-com bubble and many other strange things happen since their
bold statements, regulators no longer seem so anxious to claim credit for it
all. Now, to hear them tell it, they are mostly reacting themselves to all these
strange developments that technology has brought our way.
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· To keep focused on how radical these changes
are, and their regulatory source, perhaps the most interesting inquiries
could look into the history of exchange formation. What are the
inducements to join this Prisoner’s Dilemma game called Stock Exchange?
Did inducements include the ability to engage in the fixing of
commissions, increments, spreads, underwriting fees, information
advantages, trading rule advantages, access advantages, or other similar
“unfair” or “anticompetitive” practices? If so, how important were these
seeming antitrust violations relative to any other inducements? Did most
or all exchanges use the same basic form? Are there any that would not be
illegal under modern antitrust law? If they were illegal all along, or
became illegal when the Sherman Act passed in 1890, or when similar laws
passed in other countries, why did it take so long for antirust to catch
up to them? (I am told that the exemption from antitrust that comes with a
regulatory overseer like the SEC does not include exemption from antitrust
violations. It merely transfers the responsibility for enforcement from
the Justice Department to the SEC.) Could any stock exchanges have formed
if they had had to submit their organizing plans in advance to antitrust
authorities for approval? If not, where would capitalism be today without
them? |
Second Addendum
Trials and Error
98
million Americans received a polio vaccine between 1955 and 1963 that was found
in 1960 to contain a previously unknown monkey virus called SV40.15
This gave potentially scary meaning to work done separately in 1960 by a
researcher named Bernice Eddy, who showed that minced monkey kidneys – the
starting point for vaccine manufacture – caused tumors in mice. For her
troubles, Eddy was demoted, stripped of her lab, and forgotten. An official
study was whipped up “proving” that, although SV40 was present in the vaccine,
this was not a problem, because there was no difference in cancer rates between
vaccinated and non-vaccinated humans. Just to be safe, though, new batches of
vaccine from 1961 onward were screened for SV40. But the policy was to hush up
the story and to continue using the existing contaminated stocks until they were
used up. Good thing there was no problem with them, because this resulted in
millions of additional human carriers of SV40 by 1963.
Fast forward to 1993 and an Italian researcher named Michele
Carbone studying a rare type of lung cancer.16
Seems there are SV40 cells present, and not just hitching a ride. Seems they
played a role in causing the cancer, too. What about that 1960 study showing it
was safe? Well, it turns out that it takes 20 – 40 years for SV40 to start
wreaking havoc. Welcome to the Land of Unintended Consequences. As other
researchers repeat Carbone’s findings and look for SV40 in other previously
unknown and now not so rare cancers, sure enough, it shows up in half a dozen
types of brain cancer, a similar number of bone cancers, kidney cancer, uterine
cancer, pituitary cancer, thyroid cancer, and more. And we’d better hope it’s
not causing all these cancers, because it seems there are now many carriers
of SV40 who didn’t get it through vaccination; 6% of newborn children
born since 1980, for example, have it in their blood. And, indicating that it
may not just be passing from mothers to babies, SV40 is now present in 23% of
adult blood samples and 45% of sperm samples.
Rather than calling for more work to find out how this
potentially very troublesome virus may be spreading, what its effects are, and
how to prevent them, the medical establishment appears obsessed with trying to
discredit the studies of Carbone and others. To do otherwise will, according to
scientists at the National Institutes of Health “shake confidence in vaccines.”
The party line on SV40 is that the now dozens of peer-reviewed studies showing a
link to cancer are wrong, probably due to laboratory contamination. It is ironic
that the establishment would so quickly jump to the contamination charge. In a
separate incident, they resisted for years a well-founded and eventually
accepted contamination claim that invalidated much of their intervention-bound
research.17
Apparently, the rule is, if a contamination story undermines intervention,
ignore it; if it supports intervention, embrace it.
My second story in this vein is that of the MMR vaccine, the
combo shot for Mumps, Measles and Rubella. A British specialist in children’s
stomach problems named Andrew Wakefield stumbled upon a possible connection
between MMR and autism.18
The more he looked into it, the more it seemed that a connection might in fact
exist. Clearly, he thought, this hypothesis was worth further investigation. But
also, the more he looked, the more he was accused of undermining confidence in
vaccines, and the more his career seemed in jeopardy. Not only did few want to
help with further research, or fund it, but he was basically told to shut up. A
recent 60 Minutes on the topic repeatedly showed medical officials urging
cover-up on the grounds that, whether the MMR-autism connection existed or not,
even talking about it might cause mothers to forego having their children
vaccinated. To remind you: my point here is not to argue for this or that
hypothesis, but to suggest that research may be biased in favor of whatever
conclusions would support intervention.
My third story on vaccines is the most frightening of all, if
true. And by “frightening, if true,” I don’t mean that it is frightening if the
scary hypothesis is true (although it is), but that it is frightening if the
medical establishment is circling the wagons as much as they seem to be to avoid
looking into it. The gist of the hypothesis is that an “experimental” oral polio
vaccine given to nearly a million Africans in the former Belgian Congo in the
late ‘Fifties brought on HIV and AIDS. The disease, in any case, started there,
and at about that time. The culprit, it is now generally accepted, was a
chimpanzee virus that “jumped” over to man. The only question is whether that
occurred via “natural transfer,” such as might come through a monkey bite, or if
the jump came with the vaccine.19
The medical establishment, as you might expect, is backing natural transfer.
I’ll spare you the arguments, fascinating and frightening though they are, and
just give you one statistic: Of the $2 billion spent annually on AIDS research,
only $1 million is spent trying to find out where it came from.20
To improve the chances of finding a cure, wouldn’t it be good to know the origin
of today’s greatest medical challenge? Speaking of a cure, much of the rest of
that money is looking for a vaccine. Does anyone but me see a loop here?
When I was a kid, I think we only got 3 or 4 vaccines. Now
babies get 26 shots by the time they are 18 months old. As we increasingly rely
on vaccines for immunity – a tree-by-tree approach if ever there was one – are
we missing the danger of igniting a massive blaze in the forest that is our
immune system? These stories all seem to involve suppressions of immune
responses; suppressions that, as the first letter in the AIDS acronym suggests,
are somehow “acquired.” Could the increase in the number of diseases have
something to do with this process, either by creating new ones by accidents like
those hypothesized, or by weakening our natural immune systems’ capacity to
fight them – or both? Many of the viruses vaccinated against now used to be
controlled naturally as children passed them around to friends and family
through normal contact in early life. The usual results were relatively mild
early infections, lifetime immunity to the contacted viruses (no boosters
needed), and versatile immune systems able to mount vigorous defenses against
new threats like cancer.21
Ever since the polio threat was met and conquered (according to the conventional
wisdom, anyway), the model for how we defeated this epidemic that began in the
United States has been copied for every other significant viral disease and
potential disease the world over. Whether this is wise or not is a question that
is never raised by the medical establishment. It should be, because this is
serious intervention. What we appear to be doing is nothing less than replacing
our natural immune system with a doctor-designed one. Will it work? Is it
necessary? What are the dangers? These are forest questions, and the fact that
so few researchers ask them is highly suggestive to me of trees-before-forest
bias. In fact, not only does the medical establishment fail to ask such big
picture questions, but neither to my knowledge have any of the challengers to
the conventional wisdom mentioned earlier.
Since polio provided the modern paradigm for this
disease-by-disease approach to health, and is assumed to offer unassailable
support for its continuation, another look at the polio experience is in order.
How successful was that intervention? Polio had been around for centuries. But
it became an epidemic only when the world’s wealthiest and most
hygiene-conscious nation had the sanitary facilities and the attitude to prevent
normal early childhood infections. We didn’t know, of course, that by preventing
early contact with polio, we were also preventing relatively harmless – indeed
usually unnoticed – early infections, and the consequent immunization of most
individuals and the general public. When the first big outbreak occurred, which
began among older-than-infant children from primarily better off New York
families in 1916, it was not even considered that increased hygiene might
be a cause. And when that epidemic struck 27,000 nationwide, including 8,900 in
New York, it seemed only prudent to increase hygiene and prevent contact even
further, which is what happened. Hygiene consciousness became hygiene obsession,
as an understandably frightened nation placed its hopes in science to find a
cure, i.e., a vaccine.
The largest peacetime mobilization in our nation’s history
ensued, as the entire medical community enlisted children in orphanages,
prisons, schools – sometimes even their own sons and daughters at home – as test
subjects for the various trial vaccines. As in all wars, this one had many
casualties. But these were not soldiers dying on foreign soil, nor even children
who contracted polio at the proverbial swimming pool. These were children
deliberately given trial vaccines who were paralyzed or died. Given the
intensity of the fervor to find a cure that such sacrifice demonstrates, it is
not surprising that certain obvious facts regarding the origin and development
of the disease were overlooked. It was not noticed until later, for example,
that the most hygiene conscious groups were the most susceptible. Nor was it
noticed that the disease seemed to grow as hygiene consciousness increased, nor
that it spread to the lower classes in proportion to the degree in which fear
convinced them to imitate the hygiene habits of the wealthy. How could
researchers be expected to look into such things, when they could barely
distinguish between the two human tragedies of a child naturally getting polio,
and one who gets it as the result of a deliberately administered experiment to
improve the general welfare or to save other children. No wonder
researchers would seldom ask if these trials themselves might be sustaining or
spreading the disease, although with hindsight it is clear that this did occur
to some extent at least.
Such was the presumption that vaccines are the answer to the
polio threat, that not only were these now generally acknowledged facts
overlooked, but the equally obvious dangers of the current course are also
ignored. In order to eradicate polio entirely so that vaccinations can be
dropped, as was allegedly done with smallpox22
and is the avowed goal of the medical establishment, American schoolchildren are
required to be vaccinated. This is assumed to be necessary until all the other
countries get rid of their polio through vaccination as we have. This is
troubling for several reasons. No natural cases of “wild” polio have been
reported in the U.S. since 1979. But that doesn’t mean it’s gone from our
shores. We still see up to 10 cases per year of paralysis or death, all
of them from the continuing vaccinations. But unfortunately, even as we still
recruit our children as soldiers in this war, it is not at all clear that it is
winnable. India, for example, has been vaccinated and vaccinated, and still sees
1,000 cases a year. And, while the cost estimates for complete eradication run
into the billions, getting there will require that everyone – 100% of all people
on earth – submit to vaccination, or are otherwise shown to be non-carriers. If
any significant subset of the world’s population balks, universal eradication of
polio in the manner described by agencies like the World Health Organization
will become impossible without an equally universal mandatory vaccination
requirement.
Even if elimination of this one disease via vaccination were
possible, and even if there were no side effects, how will it be possible to
copy the polio paradigm for all the others, whether natural or man-made? Is it
going to be possible, following this disease-by-disease approach, to find a new
vaccine for each strain of each new virus that jumps from the animal kingdom, or
a new antibiotic for all the microbes that have evolved their way around the old
ones? How will we get everyone in the world to take their shots? How many shots
for how many separate viruses will they have to take? Who will pay for them?
There may be good and sufficient answers to such questions, but the one thing
that is crystal clear is that very few researchers are asking them. Until they
do, it will be hard to escape the impression that there are major unintended
consequences lurking in that forest. The failure to ask such questions is itself
evidence of bias in medical research in favor of conclusions and interpretations
that support intervention. This is the dog that didn’t bark – big time!
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