Tax Plan Deceptions Come Under Scrutiny by Inspector General

By Pam Martens and Russ Martens: December 1, 2017

U.S. Treasury Secretary Steven Mnuchin Speaking at the Institute of International Finance, April 20, 2017

U.S. Treasury Secretary Steven Mnuchin Speaking at the Institute of International Finance, April 20, 2017

On April 20 of this year, U.S. Treasury Secretary Steven Mnuchin spoke about the Trump administration’s tax plan at the Institute of International Finance. (Watch the video here.) Mnuchin described how the plan would pay for itself without adding to the national debt. He stated:

“The deal will pay for itself. Now, having said that, we fundamentally believe in dynamic scoring. So, as you know, static scoring – you change the tax code, you plug it in, you see what the cost is. So, you are correct, fundamentally you’re lowering taxes under a static score, it’s gonna cost money. Now, having said that, some of the lowering in rates is going to be offset by less deductions, in simpler taxes. So, some of it will be made up on that but the majority of it will be made up on in what we believe is fundamentally growth and dynamic scoring.

“And, you know, these are huge numbers. I mean you could have as high as $2 trillion difference in revenues over a 10-year period, depending on what you think is going to be the growth function. So the plan will pay for itself with growth.”

The United States Congress has already sentenced the next generation to a lower standard of living by virtue of its current $20.5 trillion in national debt. Just in the past fiscal year, the U.S. ran up a deficit of $666 billion. That follows deficits of $585 billion in 2016, $438 billion in 2015, $485 billion in 2014, $679 billion in 2013 and more than $1 trillion in deficits in each year from 2009 through 2012 despite extraordinary efforts to stimulate the economy following the 2008 Wall Street financial collapse.

The idea that cutting the taxes of corporations (which use their profits to buy back their own shares in order to artificially inflate share prices) and millionaires/billionaires (who own the vast majority of stocks that benefit from this share price inflation) will somehow trickle down to the real economy and the average Joe is simply another grand illusion from the Trump team.

Yesterday, the nonpartisan Joint Committee on Taxation released its analysis of just how much more debt the U.S. will be taking on if the Senate Tax Plan passes. The study found that economic growth would trim only $458 billion of the tax plan’s cost over the next decade while adding an additional $1 trillion to the national debt.

Senator Elizabeth Warren, who has spent enough time monitoring the devious deceptions of Wall Street to know a con job when she sees one, sent a letter yesterday to Eric Thorson, the Inspector General of the U.S. Treasury Department, demanding an investigation into why the Treasury Department did not release to the public its own official analysis of whether the tax plan would pay for itself. Warren wrote:

“On April 20th, Treasury Secretary Steven Mnuchin claimed that the Republican tax plan ‘will pay for itself with growth.’ In late September, Secretary Mnuchin went further, claiming that ‘not only will this tax plan pay for itself, but it will pay down debt.’ Such claims have been widely disproven by independent budgetary and economic experts. In fact, President Bush’s former Treasury Secretary, Paul O’Neill, was ‘dumbfounded by the notion that the tax cuts … would not add to the debt,’ and stated that ‘the whole thing seems astounding to me … the idea that after the most recently completed fiscal year where we had a $660 billion deficit we’re talking about a big tax cut.’

“Despite a lack of evidence to support his assertions, Secretary Mnuchin has claimed that over 100 people are ‘working around the clock on running scenarios for us’ to show that these corporate tax cuts will pay for themselves. Secretary Mnuchin ‘has promised that Treasury will release its analysis[.]’ Yet as Senate Republicans prepare to vote within the next day on the tax plan, the Department of Treasury has failed to produce any economic analysis supporting Secretary Mnuchin’s claims that the cuts will pay for themselves — in fact, they haven’t released any formal analysis of the bill’s economic impact at all.”

The New York Times reported yesterday that the Treasury’s Inspector General has confirmed that it has opened an inquiry into the matter.

Mnuchin is rapidly evolving as one of the most scandalous Treasury Secretaries in history. His Senate confirmation hearing was tarred with the tawdry details of his past business dealings and failure to disclose tens of millions of dollars in problematic assets. Since then, his wife, actress Louise Linton, has continued to set the Internet ablaze with her tone-deaf musings on the rich versus the little people and by inserting herself into the official functions of the U.S. Treasury Secretary.

At Mnuchin’s January 19 confirmation hearing, Senator Ron Wyden outlined his dubious past as follows:

“Mr. Mnuchin’s career began in trading the financial products that brought on the housing crash and the Great Recession. After nearly two decades at Goldman Sachs, he left in 2002 and joined a hedge fund. In 2004, he spun off a hedge fund of his own, Dune Capital. It was only a few lackluster years before Dune began to wind down its investments in 2008.

“In early 2009, Mr. Mnuchin led a group of investors that purchased a bank called IndyMac, renaming it OneWest. OneWest was truly unique. While Mr. Mnuchin was CEO, the bank proved it could put more vulnerable people on the street faster than just about anybody else around.

“While he was CEO, a OneWest vice president admitted in a court proceeding to ‘robo-signing’ upward of 750 foreclosure documents a week. She spent less than 30 seconds on each, and in fact, she had shortened her signature to speed the process along. Investigations found that the bank frequently mishandled documents and skipped over reviewing them. All it took to plunge families into the nightmare of potentially losing their homes was 30 seconds of sloppy paperwork and a few haphazard signatures.

“These kinds of tactics were in use between 2009 and 2014, a period during which the bank foreclosed on more than 35,000 homes. ‘Widow foreclosures’ on reverse mortgages – OneWest did more of those than anybody else. The bank defends its record on loan modifications, but it was found guilty of an illegal practice known as ‘dual tracking.’ One bank department tells homeowners to stop making payments so they can pursue modification, while another department presses on and hurtles them into foreclosure anyway.”

During Mnuchin’s confirmation hearing it was also reported that while he was in charge, OneWest had foreclosed illegally on active-duty U.S. military service members. At the close of the confirmation hearing, Senator Wyden reported Mnuchin’s failure to comply initially with financial disclosure rules, stating:

“Mr. Mnuchin, a month ago you signed documents and an affidavit that omitted the Cayman Island fund, almost $100 million of real estate, six shell companies and a hedge fund in Anguilla. This was not self-corrected. The only reason it came to light was my staff found it and told you it had to be corrected.”

Nobel Laureate Stiglitz Says Bitcoin Should Be “Outlawed”

Bitcoins and BubblesBy Pam Martens and Russ Martens: November 30, 2017

Bitcoin has soared this year by more than ten-fold, defying all of the Wall Street veterans who have compared it to the Tulip Bubble and/or a Ponzi scheme. That doesn’t mean that Bitcoin is a legitimate investment; it just means that bubbles have no set expiration date.

The Nobel laureate economist, Joseph Stiglitz of Columbia University, appeared on Bloomberg television yesterday and had this to say about Bitcoin:

“One of the main functions of government is to create currency. And Bitcoin is successful only because of its potential for circumvention, lack of oversight. So it seems to me it ought to be outlawed. It doesn’t serve any socially useful function.”

Consider the remarks Stiglitz made yesterday to our more detailed assessment along the same lines back in 2014. We wrote:

“The business writers at Reuters are also dead wrong on Bitcoin being like other currencies whose ‘value depends on people’s confidence in it.’ Let’s take the U.S. dollar. Backing the use of the U.S. dollar as a world currency is the following: a Congress made up of 435 Representatives in the House and 100 Senators in the Senate; 535 people elected from all over the United States who have the power to tax the income of every American receiving wage, dividend, interest or even Social Security income at whatever rate they see fit in order to pay the Nation’s bills and debt obligations to other countries.

“There are two big mechanisms underlying the confidence in the U.S. dollar. Unlike many other countries which have a not-so-foolproof system of collecting taxes, in the United States Federal income tax is deducted from workers’ paychecks and sent off to the Federal government by the employer before the worker gets his hands on his paycheck. Every worker, therefore, becomes part of the store of value in the U.S. dollar.

“Next comes the billions in taxes owed on interest and dividends. Those are reported to the Internal Revenue Service under the individual’s social security number by the financial institution or company declaring the interest or dividends, leaving no escape hatch for not reporting and paying the taxes owed.

“When an individual or a financial institution tries to game the system to dodge paying their share of taxes to support the roads, schools, tunnels, bridges, national parks, and Federal law enforcement protections provided with those taxes, the government has both the ability and eager willingness to lock you up and/or make a public spectacle of you. Just yesterday, Credit Suisse was outed by Senators Carl Levin and John McCain and the U.S. Senate’s Permanent Subcommittee on Investigations for aiding and abetting tax cheats. In 2009, Swiss bank UBS was outed on similar charges and paid $780 million to settle the matter.

“A digital currency that is backed with nothing tangible, that has no legislated power of taxation to support the currency, that has no Federal regulation over the people offering the currency, that has no independent, taxpayer-financed police to prevent counterfeiting of the currency, is not even a Tulip Bubble. A tulip is a tangible thing. This is just a bubble.” (Read the full article here.)

Unregulated currencies also have the habit of being used to facilitate crime. In 2013, the U.S. Department of Justice shut down an online outfit called Silk Road that used Bitcoins as an exclusive payment mechanism. On November 18, 2013, Mythili Raman, Acting Assistant Attorney General of the Criminal Division of the Justice Department, testified as follows before the U.S. Senate Committee on Homeland Security and Governmental Affairs:

“…the Department took action against one of the most popular online black markets, Silk Road.  Allegedly operated by a U.S. citizen living in California at the time of his arrest, Silk Road accepted Bitcoins exclusively as a payment mechanism on its site. The Department’s complaint alleges that, in less than three years, Silk Road served as a venue for over 100,000 buyers to purchase hundreds of kilograms of illegal drugs and other illicit goods from several thousand drug dealers and other criminal vendors.  The site also purportedly laundered the proceeds of these transactions, amounting to hundreds of millions of dollars in Bitcoins.  In addition to arresting the site’s operator and shutting down the service, the Department to date has seized over 170 thousand Bitcoins, valued as of this past Friday, November 15, 2013, at over $70 million. A separate indictment charges Silk Road’s operator with drug distribution conspiracy, attempted witness murder, and using interstate commerce facilities in the commission of murder-for-hire.  With regard to the murder-related charges, the indictment alleges that the Silk Road operator paid an undercover federal agent to murder one of the operator’s employees.”

Bitcoin is now operating in the realm of the Madoff Ponzi scheme: Plenty of people understand that it’s going to collapse because it is based on an unsustainable illusion. Plenty of people are warning regulators to not allow this illusion to continue. But, hey, this is also the land of the libertarian Koch Brothers where the workings of free markets are sacrosanct and can’t be tampered with – even when it’s inevitable that they will end up disgracing the legitimate marketplace.

Trump Now Says Wall Street Is the Victim, Not the Villain

Trump Tweet Nov 25, 2017-ii

By Pam Martens and Russ Martens: November 29, 2017

“Populist” candidate for President, Donald Trump, railed against the “political establishment” and Wall Street elites who were “getting away with murder.” On October 26, 2016, just days before the Presidential election, Trump spoke at a rally in Charlotte, North Carolina and promised to uphold the plank in the Republican Party platform to break up the big banks by restoring the Glass-Steagall Act. He stated:

“The policies of the Clintons brought us the financial recession — through lifting Glass-Steagall, pushing subprime lending, and blocking reforms to Fannie and Freddie. Two friendly names but they’re not so friendly. It’s time for a 21st century Glass-Steagall and, as part of that, a priority on helping African-American businesses get the credit they need.”

Now, as the sitting President, the former populist candidate has become the embodiment of the political establishment he railed against. He has stacked his administration with former bankers from Goldman Sachs; he has placed deeply conflicted Wall Street cronies in key regulatory posts; and he is promising to roll back critical financial reforms. His Treasury Secretary, Steve Mnuchin, has disavowed any intention to reinstate the Glass-Steagall Act.

To the careful observer, it would appear that the American people have, once again, been played for fools by billionaires who no longer need to hide behind a dark political curtain but have simply seized the reins of power for themselves in broad daylight.

Trump’s latest propaganda ploy is reminiscent of how the Murdoch-owned Wall Street Journal runs its editorial and opinion pages – using every opportunity to portray Wall Street as the victim of government overreach rather than acknowledging the thoroughly documented reality that Wall Street has been looting the public for the past century.

In a Tweet on November 25 of this year, Trump stated: “Financial institutions have been devastated and unable to serve the public.”

Consider that statement against the following facts. On June 7, Fortune Magazine provided the names of the 10 most profitable companies for 2016. Four of the 10 were the largest Wall Street banks. JPMorgan Chase had reported $24.7 billion in profits for 2016; Wells Fargo weighed in with $21.9 billion; Bank of America posted $17.9 billion in profits while the serially charged malefactor Citigroup reported $14.9 billion in 2016 profits. That’s just four banks with a total of $79.40 billion in profits, which represents 51 percent of the $157 billion earned by all 5,112 insured commercial banks in the U.S.

To any rational human being, the above figures would be all the proof one needs that banking in the United States is dangerously concentrated in mega Wall Street banks and these banks must be broken up.

Derivative statistics also show just how lax Federal regulators have been under both Obama and Trump in reining in the abuses that collapsed Wall Street and the U.S. economy in 2008. According to the quarterly derivative reports coming out of the national bank regulator, the Office of the Comptroller of the Currency (OCC), at the end of the second quarter of 2007, prior to the 2008 financial collapse and Dodd-Frank “financial reform” legislation, the 25 largest bank holding companies held a total of $160.4 trillion in notional amounts of derivatives. A decade later, the 25 largest bank holding companies hold a total of $252 trillion in notional amounts of derivatives as of June 30, 2017 according to the OCC.

These unfathomable levels of derivative holdings are predominantly held at the insured depository institution – the FDIC insured bank where the taxpayer is on the hook for losses. Making the situation exponentially more dangerous is that the OCC reports the following in its June 30, 2017 assessment of derivatives:

“A small group of large financial institutions continues to dominate derivative activity in the U.S. commercial banking system. During the second quarter of 2017, four large commercial banks represented 89.6 percent of the total banking industry notional amounts [of derivatives]…”

Those four banks are Citigroup’s insured depository, Citibank; JPMorgan Chase, Goldman Sachs Bank USA and Bank of America. Citigroup is the bank that blew itself up in 2008 and required the largest U.S. taxpayer bailout in U.S. history, including: $45 billion in capital infused into Citigroup by the U.S. Treasury to prevent its total collapse; the government guaranteed over $300 billion of Citigroup’s assets; the Federal Deposit Insurance Corporation (FDIC) guaranteed $5.75 billion of its senior unsecured debt and $26 billion of its commercial paper and interbank deposits; and the Federal Reserve secretly sluiced $2.5 trillion in almost zero-interest loans to Citigroup from 2007 to at least the middle of 2010.

If Vanguard Is Right, You’ll Need to Save More For Retirement

By Pam Martens and Russ Martens: November 28, 2017

Broken Piggy BankVanguard is one of the largest mutual fund companies in the world with 20 million investors and approximately $4.5 trillion in global assets under management as of September 30, 2017, according to its website. When it expounds on the outlook for the stock market, people tend to listen closely.

Yesterday, Vanguard issued its economic and stock market outlook for the medium term, writing: “For 2018 and beyond, our investment outlook is modest, at best. Elevated valuations, low volatility, and secularly low interest rates are unlikely to be allies for robust financial market returns over the next five years.”

Exactly how “modest” does it expect stock market returns to be over the medium term? The report goes on to define “modest” as follows:

“Based on our ‘fair-value’ stock valuation metrics, the medium-run outlook for global equities has deteriorated a bit and is now centered in the 4% – 6% range. Expected returns for the U.S. stock market are lower than those for non-U.S. markets, underscoring the benefits of global equity strategies in the face of lower expected returns.”

If your retirement savings strategy has factored in an annualized stock market return of 7 percent or higher and Vanguard is right about the potential for a return of 4 to 6 percent, those planning to retire in less than 10 years will need to either save more for retirement or extend out the date of retirement.

This reality may already be setting in among millions of pre-retirees as they watch friends and family members who have already retired tighten their belts as a result of an unprecedented, prolonged low rate of return for fixed income investors. Retirees who were earning 4 and 5 percent on U.S. Treasury securities or Certificates of Deposit prior to the financial crash in 2008 have seen their interest income cut by half or more since the crisis.

According to Vanguard’s new report, bond yields are not likely to see any significant uptick next year. The report notes: “And despite the risk for a short-term acceleration in the pace of monetary policy normalization, the risk of a material rise in long-term interest rates remains modest. For example, our fair-value estimate for the benchmark 10-year U.S. Treasury yield remains centered near 2.5% in 2018.”

The low yield in Treasuries, CDs and quality corporate bonds has obviously fueled at least part of the runup in stock prices, leading to what many believe is an unsustainable stock bubble.

Another hurdle for retirees is nailing down how much the fees embedded in their mutual funds in their 401(k) plans are draining from their retirement savings.

John Bogle is the legendary founder of Vanguard and served as its Chairman and CEO from 1974 to 1996. In 2013, he appeared on the PBS program, Frontline, to share an amazing bombshell: If you work for 50 years and receive the typical long-term return of 7 percent on stock funds in your 401(k) plan and your fees are 2 percent, almost two-thirds of your account will go to Wall Street.

Titled The Retirement Gamble, the Frontline program was written by the outstanding team of Martin Smith and Marcela Gaviria. The conversation between Bogle and Smith, who also served as moderator, went like this:

Bogle: Costs are a crucial part of the equation. It doesn’t take a genius to know that the bigger the profit of the management company, the smaller the profit that investors get. The money managers always want more, and that’s natural enough in most businesses, but it’s not right for this business.

Smith: Bogle gave me an example. Assume you’re invested in a fund that is earning a gross annual return of 7 percent. They charge you a 2 percent annual fee. Over 50 years, the difference between your net of 5 percent — the red line — and what you would have made without fees — the green line — is staggering. Bogle says you’ve lost almost two thirds of what you would have had.

Bogle: What happens in the fund business is the magic of compound returns is overwhelmed by the tyranny of compounding costs. It’s a mathematical fact. There’s no getting around it. The fact that we don’t look at it— too bad for us.

Smith: What I have a hard time understanding is that 2 percent fee that I might pay to an actively managed mutual fund is going to really have a great impact on my future retirement savings.

Bogle: Well, you have to rely on somebody to get out a compound interest table and look at the impact over an investment lifetime. Do you really want to invest in a system where you put up 100 percent of the capital, you the mutual fund shareholder, you take 100 percent of the risk and you get 30 percent of the return?

Smith brings up a compounding calculator on his laptop. He shows viewers the results:

Smith: Take an account with a $100,000 balance and reduce it by 2 percent a year. At the end of 50 years, that 2 percent annual charge would subtract $63,000 from your account, a loss of 63 percent, leaving you with just a little over $36,000.

Wall Street On Parade double-checked Bogle’s math. We pulled up a compounding calculator on line. We assumed an account with a $100,000 balance and compounded it at 7 percent for 50 years. That results in a balance of  $3,278,041.36. Next, we changed the calculation to a 5 percent return (reduced by the 2 percent annual fee) for the same $100,000 over the same 50 years. That delivered a return of $1,211,938.32. That’s a difference of $2,066,103.04 – the same 63 percent reduction in value that Smith’s example showed.

A Private Citizen Would Be in Prison If He Had Citigroup’s Rap Sheet

By Pam Martens and Russ Martens: November 27, 2017

citigroup-logoSince its financial meltdown in 2008 and unprecedented bailout by the U.S. taxpayer, Citigroup (parent of Citibank) has been repeatedly charged by its Federal regulators with odious crimes against its pooled mortgage investors, credit card and banking customers, student loan borrowers, and for its foreclosure frauds. It has paid billions of dollars in fines for its past misdeeds while new charges pile up. In 2015, it became an admitted felon for participating in rigging foreign exchange markets. In short, Citigroup is a lawbreaking recidivist. If it were a mere human, it would be serving a long prison term. Instead, its fines for charges of egregious acts are getting smaller, not larger.

Last Tuesday, the Consumer Financial Protection Bureau (CFPB), which typically has a good track record of holding the big Wall Street banks accountable for their misdeeds, imposed an unusually feeble fine against Citibank for a litany of abuses against student loan borrowers. The CFPB ordered Citi to pay $3.75 million in restitution and to pay a $2.75 million fine. When combined with the fact that the CFPB did not make Citibank admit to the charges, this amounts to a slap on the wrist to a serial lawbreaker. (See Citigroup/Citibank’s history of misconduct below.)

Adding further insult to the American public, the Board of Directors of Citigroup has kept the same CEO in place for more than five years as these serial abuses of the public trust piled up. Michael Corbat has been CEO of Citigroup since October 2012.

The CFPB’s latest action against Citibank, where it was charged with abusing vulnerable and unsuspecting college students, brought to mind a Harper’s article by Andrew Cockburn in April 2015. Cockburn had traced the history of how Sandy Weill had parlayed Commercial Credit into the too-big-to-fail Citigroup, which continues to own the commercial bank, Citibank. Cockburn wrote:

“Weill had recently been eased out from Shearson Lehman/American Express [in 1985], a financial conglomerate he had helped to build. Eager to get back in the game, he bought a Baltimore firm called Commercial Credit. In the view of Weill and his protégé, Jamie Dimon [now CEO at JPMorgan Chase], their new acquisition was in the beneficent business of supplying ‘consumer finance’ to ‘Main Street America.’ Their office receptionist, Alison Falls, thought otherwise. Overhearing their conversation at work one day, she called out, ‘Hey, guys, this is the loan-sharking business. Consumer finance is just a nice way to describe it.’

“Falls had it right. Commercial Credit made loans to poor people at predatory interest rates. Strapped to pay off their loans, borrowers were encouraged to refinance, with added fees each time. Gail Kubiniec, who was then an assistant sales manager at the company’s branch office in Tonawanda, New York, remembers that the basic aim was to lend money to ‘people uneducated about credit. You could take a five-hundred-dollar loan and pack it with extra items like life insurance—that was very lucrative. Then you could roll it over with more extra items, then reroll the new loan, and the borrower would go on paying and paying and paying.’ ”

This is what the CFPB charged Weill’s progeny, Citibank, with last Tuesday:

“Citibank misled borrowers into believing that they were not eligible for a valuable tax deduction on interest paid on certain student loans. The company also incorrectly charged late fees and added interest to the student loan balances of borrowers who were still in school and eligible to defer their loan payments. Citibank also misled consumers about how much they had to pay in their monthly bills and failed to disclose required information after denying borrowers’ requests to release loan cosigners.”

When will the U.S. Justice Department begin to take serial lawbreakers on Wall Street as seriously as it takes petty criminals on Main Street?

The following is just a sampling of charges brought against Citigroup and its affiliates since December 2008:

December 11, 2008: SEC forces Citigroup and UBS to buy back $30 billion in auction rate securities that were improperly sold to investors through misleading information.

July 29, 2010: SEC settles with Citigroup for $75 million over its misleading statements to investors that it had reduced its exposure to subprime mortgages to $13 billion when in fact the exposure was over $50 billion.

October 19, 2011: SEC agrees to settle with Citigroup for $285 million over claims it misled investors in a $1 billion financial product.  Citigroup had selected approximately half the assets and was betting they would decline in value.

February 9, 2012: Citigroup agrees to pay $2.2 billion as its portion of the nationwide settlement of bank foreclosure fraud.

August 29, 2012: Citigroup agrees to settle a class action lawsuit for $590 million over claims it withheld from shareholders’ knowledge that it had far greater exposure to subprime debt than it was reporting.

July 1, 2013: Citigroup agrees to pay Fannie Mae $968 million for selling it toxic mortgage loans.

September 25, 2013: Citigroup agrees to pay Freddie Mac $395 million to settle claims it sold it toxic mortgages.

December 4, 2013: Citigroup admits to participating in the Yen Libor financial derivatives cartel to the European Commission and accepts a fine of $95 million.

July 14, 2014: The U.S. Department of Justice announces a $7 billion settlement with Citigroup for selling toxic mortgages to investors. Attorney General Eric Holder called the bank’s conduct “egregious,” adding, “As a result of their assurances that toxic financial products were sound, Citigroup was able to expand its market share and increase profits.”

November 2014: Citigroup pays more than $1 billion to settle civil allegations with regulators that it manipulated foreign currency markets. Other global banks settled at the same time.

May 20, 2015: Citicorp, a unit of Citigroup becomes an admitted felon by pleading guilty to a felony charge in the matter of rigging foreign currency trading, paying a fine of $925 million to the Justice Department and $342 million to the Federal Reserve for a total of $1.267 billion. The prior November it paid U.S. and U.K. regulators an additional $1.02 billion.

May 25, 2016: Citigroup agrees to pay $425 million to resolve claims brought by the Commodity Futures Trading Commission that it had rigged interest-rate benchmarks, including ISDAfix, from 2007 to 2012.

July 12, 2016: The Securities and Exchange Commission fined Citigroup Global Markets Inc. $7 million for failure to provide accurate trading records over a period of 15 years. According to the SEC: “CGMI failed to produce records for 26,810 securities transactions comprising over 291 million shares of stock and options in response to 2,382 EBS requests made by Commission staff, between May 1999 and April 2014, due to an error in the computer code for CGMI’s EBS response software. Despite discovering the error in late April 2014, CGMI did not report the issue to Commission staff or take steps to produce the omitted data until nine months later on January 27, 2015. CGMI’s failure to discover the coding error and to produce the missing data for many years potentially impacted numerous Commission investigations.”