This action might not be possible to undo. Are you sure you want to continue?
Aosociate General Counsel LaSalle et Van Buren
Chicago, Hanoi, 80505 312 786-7488
May 16, 1988
Laurence Storch, Esquire Storch & Brenner
1001 Connecticut Avenue, N.W.
Washington, D.C. 20036 Dear Mr. Storchl We are in receipt of your April 21, 1988 letter to the Exchange. Your letter appears to misperceive Rule 6.51(c). The Rule contemplates that the price and size of off-board transactions, just . as on-floor transactions, will be "made public," in the sense of providing such information to "the tape," not in the sense of having a public file of such information. In any event, our records do not reflect any off-board transactions during the period October 16 through November 20, 1987. , We note that you are counsel to plaintiffs in litigation in which the Exchange is a defendant. Unless further communications have no conceivable direct or indirect relationship to that litigation, we request that further communications from your office be directed to Paul E. Dengel or me. Yours sincerely,
LOCl/ CO2414113CTICUT AVENVE,
STORCII & BRENNER N. W.
WASHINOTCM, D. C. 20036 MOM 4041-0000
May 26, 1988 Ill!,
Paul E. Dengel, Esq. Schiff, Hardin & Waite 7200 Sears Tower 233 South Wacker Drive Chicago, Illinois 60606 Re: Pompano-Windy City Partners, Ltd. et al. v. Bear, Stearns Inc. & Co. et al. Itan212=§2CIL2.910(EEL) Dear Mr. Dengel: On May 2, 1988, we requested orally that your client OCC produce the Daily Position Reports and Daily Margin Reports pertaining specifically to accounts of our clients in this matter. You said .that you would take the matter under advisement. We have not heard Luther from you on the subject. Our clients are entitled to the documents we seek, apart from whatever rights they may have in the litigation, as customers, and as the direct or beneficial holders of the accounts in question. Indeed, we have no doubt that the OCC has a fiduciary obligation to our clients to produce these documents and that its failure to do so is a willful and outrageous refusal of its obligations. This refusal could itself form an adequate basis for new claims against the OCC. On May 16, 1988, Mr. Xrieger of the CBOE wrote to us that CBOE "records do not reflect any off-board transactions during the period October 16 through November 20, 1987." We therefore suspect that losing trades alleged by Bear Stearns to have occurred during that period never took place. In that event, it would appear difficult to distinguish Bear Stearns' "absorption" of our clients' accounts from the type of "absorption" addressed, for example, by Ill.Ann.Stat. 0.38, §16 - 1 and similar statutes.
Paul E. Dangel, req. May 26, 198g Page 2
The documents we seek are directly relevant to these issues. Failure to produce them may constitute an intentional cover-up of serious wrong-doing and may be a basis for liability under 18 U.S.C. §2, in f er Alla, as well as civilly. We therefore demand that the documents in question produced immediately.
Finally, it appears that the OCC•• CBOB, and your firm are uniquely well-situated to know about the dubious transactions Because of this, and because of your relationship to involved. the options market and options offerings, you three have special obligations to bring apparent wrong-doing to the attention of the
appropriate law enforcement and regulatory authorities.
urs sins= ely,
oel F. B v nner JFB/pkt
bcc: Mr. Stephan J. Lawrence cc: Files: JF3 Chron Sp Chrot S Chron ACR Chron S&B Matter No.
Jun.u.1 '88 15:08 SC-IFF HARDIN & WAITE
SCIUFF HARDIN & WAITE
A Pattrkstvgpludint; 0006,111011
7200 Bests Tower, Chicapo,1111n014 seeps Telephone (312) 878-1000 Tint 810-2214403
1101 Connecticut Avenue. N. ‘N., Washington, D.C. 200: Telephone (202) 857-0800 Vox 8)-(W 04580
June 3, 1988
Mr.. Noel P. Brenner
Storch & Brenner 1001 Connecticut Ave., N.W. Washington, D.C. 20036 Ret Pornwto-Wirady City Partnere, Ltd. Dear Mr. Brennen I have received louts' telecopied letter of May 26, 1988. For the reasons set forth below, 0CC refuses the "demand" that you make in your letter. Your demand is improper because it attempts to circumvent the limitations on discovery that Magistrate Lee imposed during the conferences on April 6, 1988 and May 12, 1988. I informed you when I took this matter under advisement earlier that these documents therefore would be produced only if your clients have some right to these documents that is independent of the discovery process. My inquiries have revealed no such independent right, and the bald assertions in your letter add nothing. The account records that 0CC maintains are the accounts of its Clearing Members, such as Bear Steams. The Daily Position Reports and Daily Margin Reports that you seek therefore deal with the accounts of Bear Stearns, not with any accounts that your clients maintain with OCC. Unless authorized by Bear Stearns or appropriately required by court action, 0CC does not believe that it would be appropriate to provide these reports to you. Any request for access to these reports therefor. should be addressed to Bear Stearns, The foregoing comments should not be interpreted to mean that the Daily Position Reports and Daily Margin Reports that 0CC provides to Bear Stearns contain information "pertaining specifically to accounts" of your clients. In essence, your letter demands production of these reports because you deem them to be relevant to the lams raised by your clients' controversy with Bear Stearns, which is the subject of the present litigation. If these documents are relevant to the present action, they will be produced when the rulings of the magistrate so require. However, you have supplied no reason why 0CC should or may voluntarily produce documents pertaining to Bear Stearns' accounts absent an appropriate ruling. your letter is not threatening our clients or our firm with civil or criminal exposure if we do not comply with your demand, Our clients are not responsible for and have made no investigation of Bear Stearns' allegations of "loving trades" or of your suspicions that
With respect to the third and last paragraph in your letter, I trust that
11 ••••• •s • V V 1.0%.• Ir...PI • • • • WI I 0 #
•s• •••• •
JUN.03 'Ea 15:09 SCHIFF HARDIN & WAITE
SCHIFF HARDIN & WAITE
Mr. Joel Ir. Brenner Starch & Brenner June 3, 1888 Page 2
those trades never took place. OCC and CBOB each have specified, but different, self-regulatory responsibilities . under the law, The discharge of those responsibilities is not dependent on whether 000 complies with your demand. insofar as our firm is concerned, we are lawyers who receive specific assignments from our clients from time to time, and our responsibilities do not include investigation of your personal aUVicions concerning the behavior of third parties. Sincerely,
Paul E. Dengel
cot Stephen L, Rather
1001 CONNECTICUT AVENUE, N. W.
WASHINGTON, D. C. 20036 (202) 452-0900 TELEX 201250
June 7, 1988
Paul E. Dengel, Esquire Schiff Hardin & Waite 7200 Sears Tower Chicago, IL 60606 Re: OCC accounts held for the benefit of Pompano Windy-City Partners, Ltd., East-Wind
Associates and Stephan J. Lawrence
Dear Mr. Dengel: We have received your letter of June 3 via telefax. You state in your third paragraph: "The account records that OCC maintains are the accounts of its Clearing Members, such as Bear Stearns." Accordingly, you conclude that it would be inappropriate to provide these reports to us. Your statement is not correct. The account agreements published by OCC and entered into by OCC directly with our respective clients state that while the accounts in question may have been maintained y Bear Stearns, they were maintained for our clients and were the accounts of our clients. The agreements, which are required under Article VI, Section 3 of OCC's By-Laws, all refer to "positions held by it [i.e., our client] or for its account." Bear Stearns' role as Clearing Member is to maintain the "Account" on our clients' behalf. There are explicit references to our clients' transactions through the account and its positions in the account. Accordingly, any account maintained by Bear Stearns at OCC relating to any of our clients was maintained by Bear Stearns as the agent for that client, for that client's benefit. The agency
/CH 8e BRENNER
Paul E. Dengel, Esquire June 7, 1988 Page 2
relationship was disclosed -- indeed its was insisted upon by OCC -- and your firm and OCC were aware of it. We therefore request that you reconsider the position taken in your letter of June 3, as it rests on unsupportable grounds and is contradicted by language published by OCC. Insofar as our former agent, Bear Stearns, may have instructed you not to produce the documents we seek, this letter hereby countermands those instructions. In all matters regarding accounts held for the entities referred to above or for Mr. Lawrence, OCC may take instructions only from us. The Daily Position Reports and Daily Margin Reports we seek pertain specifically to' our clients' named accounts and constitute the statements for those accounts; you could not in good faith deny this, and I note that you have not done so. Indeed, the concept of a position or margin report is meaningful only in regard to a specific individual or firm. If you are uncertain of this, a five-minute conversation with your client would clear it up. As to the last paragraph of our letter of May 26, regarding civil and criminal liabilitiy resulting from the intentional cover-up of fraudulent transactions, we will let it speak for itself. Your response to it, denying that your clients have made a relevant investigation or have an obligation to do so, appears inaccurate, however. We remind you that your clients OCC and CBOE have SRO responsibilities. We remind you that your client OCC has a "Daily Options Clearing Corp. Compliance Tape" specifically designed to recognize fraudulent activities. We remind you that your client CBOE has in fact conducted an investigation sufficient to have stated in a letter to us dated May 16, 1988 that "[its] records do not reflect any off-board transactions during the period October 16 through November 20, 1987." Apropos of the last point, we enclose reports by Bear Stearns for October 23, 1987 (for example) purporting to show "liquidating private sale" transactions effected by Bear Stearns from Pompano's OCC account to an undisclosed Bear Stearns account. These transactions were accomplished through "journal entries" that appear fraudulent in that they reflect post-dated non-market prices. In view of the positions taken by you, it
Paul E. Dengel, Esquire June 7, 1988 Page 3
appears that OCC nevertheless consented ) to and effected the transactions in question, thus knowingly participating in Bear Stearns' fraudulent scheme and violating its fiduciary and contractual obligations to our clients, the terms of the Option Disclosure Document ("ODD"), the terms of the purported "Prospectus" you supplied to us, and federal securities laws, including the antifraud provisions. You are too modest about Schiff Hardin & Waite's role in these matters. Your firm expertized the "Prospectus" which, it now appears, may have been written intentionally to exclude the purchase of options-write transactions from its scope, notwithstanding the terms of the ODD. You have not responded to our written query of May 5,, 1988, about whether your firm takes the position that they are so covered. The OCC's co-defendants may find that this issue merits their attention, since if options writing transactions are not covered by the "Prospectus," then they will apparently have participated in widespread violations of the securities laws, including the antifraud provisions, and would face substantial liability either primarily, or secondarily as Participating Organizations and controlling persons of the OCC and under the indemnity agreement. Your firm would not appear uninvolved in such violations. Your clients' reckless or intentional disregard of their duties to undertake a full investigation of the activities of the Bear Stearns defendants, and OCC's refusal to produce documents pertaining to our clients' accounts, is consistent with a deliberate policy to cover up serious malfeasance by them and their co-defendants. That such a policy appears to be in place is evidenced by the letter form Mr. Hender of OCC to Mr. Wilson of NASD, dated May 9, 1988 stating that "it would be unwise for defendants to engage in disputes among themselves at this stage of the proceeding regarding indemnification rights." We do not believe that a jury will ignore such evidence. Schiff Hardin & Waite has obvious conflicts of interest between itself and each of its clients, who themselves have conflicting interests. Ordinarily such conflicts would be no concern of ours. Here, however, where the conflicts appear to
1 See, OCC By-Laws, Article VI, Section 1, which states: "All exchange transactions shall be cleared through the Corporation, and no other transaction shall be cleared through the Corporation without its consent."
/TORCH 8C BRENNER
Paul A. Dengel, Esquire June 7, 1988 Page 4
affect OCC's ability or willingness to meet its fiduciary obligations to our clients -- obligations to investigate and to produce documents -- we object strenuously to them. Based on our review of the OCC's history, it appears that Schiff Hardin & Waite was present at the creation and has played a unique and important role in OCC affairs since then. Your professed lack of knowledge of OCC's standard account agreement, combined with your statement that you (Schiff Hardin & Waite) are merely lawyers who follow specific directions, could be viewed as an attempt to disguise or minimize your firm's significant potential liability by projecting an image of ignorance in matters basic to the case. This course of conduct appears designed to minimize Schiff Hardin & Waite's potential liability to the OCC's codefendants as well as to plaintiffs. We reiterate our formal demand for the Daily Position Reports and Daily Magin Reports and urgently request that you reconsider your refusal to produce them. We also reiterate our request that you state the OCC's position on whether its purported "Prospectus" covers the purchase of options-write transactions. Please advise at your very earliest convenience.
Joel F. Brenner
cc: All Counsel
SCHIMULE A aF ?CFM CA-1
of Registrant as stated in Item = of 7orm :A-1.
THE OPTIONS CLEARING CORPORATION
Item of Form fTda*ti ,-'7)
Res,:cnse liquidations, plus any fees or charges owing to OCC from the suspended Clearing Member, should exceed the amounts available to OCC in the Suspended Clearing Member's Liquidating Settlement Account to offset such Liabilities (consisting of cash margin deposits of the suspended Clearing Member, amounts realized by OCC from the liquidation of non-cash margin deposits and from issuers of letters of credit, amounts realized by OCC upon liquidation of long option positions on which OCC had a lien in accounts of the suspended Clearing Member, and the suspended Clearing Member's contribution to the Clearing Fund), a loss in an amount equal to the excess would be sustained. Such loss would be subject to reimbursement out of the Clearing Fund unless OCC elected pursuant to Article VIII, Section 5(b) of the By-Laws to charge such loss in whole or in part to OCC's current earnings, and would be reduced by the set-off of any amounts owing from OCC to the suspended Clearing MeMber and any recovery from such Clearing Member.
2. OCC might also sustain a loss in the event of fraudulent or other criminal conduct by a Clearing Member, to the extent that losses of such a nature are not covered by insurance. OCC maintains a Clearing Fund, in accordance with the provisions of Article VIII of the OCC By - Laws and Chapter X of the OCC Rules, as protection against the types of losses enumerated in Sections 1 and 5 of Article 7111 of the OCC By-Laws. Chapter VI of the OCC Rules requires thd , deposit of margin, on a daily basis, in respect of each short position (including short positions to which exercise notices have been assigned, pending exercise settlement) maintained with OCC
JAN-17-10 MON 19:50 COLE CORETTEgrABRUTYN
Law ()Hi co
E CORE 1 '1 E & ABRWYN
A rrtdessiona I Corporation
2100-1 Mark A. Cymrot C4f4( January 17, 1989 Lawrence v. Bear Stearns
I had a telephone conversation today with Paul Dengel to follow up on our settlement discussions.
We agreed that the discussions could not be used by either party as an admission. We said that he understood the information would "enter into our collective memories" and might provide a "road map" for discovery, but they would not be the basis of a question at a deposition or some other similar use. Based on prior conversations, our discussions have been proceeding on the basis that he would make representations to us about facts (i.e. the first step). If we felt that those representations provided a basis to settle, then he would provide evidence which could be admitted in a court proceeding to support the representations (i.e. the second step.) We had previously discussed three questions: 1. What role did 0CC have in the transfer of the Pompano accounts to Bear Stearns; 2. What knowledge did 0CC and CBOE have concerning the actions BS were taking with respect to the Pompano accounts; 3. What is CBOE's interpretation of its arbitration rules, particularly Sec. 18.1(d). We previously had questioned Mr. Dengel on the basis for his assertion that OCC could rely upon instructions from clearing members. He pointed to the following authority for his position and said: 1. Combined Market-Maker Agreement which says (according to Mr. Dengel) that the Clearing Corporation is authorized to rely on notices by the clearing member or other persons. This includes notices to transfer accounts.
-22. By-Laws - Art. 6 - Sections 12(f) and 13(f) set forth the conditions under which long and short positions can be closed In substance, short positions remain in force until out. transferred to another account at a clearing member or another clearing member. Under 0CC rules, transfers of positions can be authorized by the clearing member. The OCC does not examine whether the transfer is in violation of any contract or rules that apply between the clearing member and its customer. From the OCC's point of view, the positions are the property of the clearing member. 0CC does not have to be aware of or deal with anyone other than the clearing member otherwise it cannot operate. Art. 6 - Sec. 9(c) - provides indirect authority, 3. Dengel says. It says the registered owner is the clearing member. 4. Art. 6 - Sec. 3(c)(iv) - gives the clearing corporation authority to close a market-maker account without giving notice. This section applies only between the OCC and the market-maker, It does not apply to BS's obligations. Dengel says that OCC only has to deal with the clearing member and not with the market-maker. An instruction which is contrary to the agreement between the clearing member and the market-maker is not the business of the OCC. The OCC can rely upon the instructions of the clearing member and would not know what other agreements applied to the transaction. I pointed out that an action which is otherwise lawful may become unlawful if the person knows that the action is part of a scheme to defraud. In other words, if 0CC carried out instructions while knowing that BS was defrauding Pompano, OCC would have participated in the fraud. Mr. Dengel said that he was aware of that theory. He said that he had checked with those who he thinks should have known of the problem if anyone at 0CC knew - the people who assessed risk at OCC. 1. He said that no one to his knowledge had information about BS's problem with Pompano or its other market makers during the week of October 19-26. 2. He said 0CC was looking at position risk - which clearing members would have problems if the market went the wrong way. BS did not show up on these status reviews. 3. The people he spoke with said that they had no conversations with BS about its own positions or the positions of the market makers.
-3He said that if we decided to proceed to the second step of the discussion that he would have to prove these facts to us and provide names and documents. On the question of what happened to the Pompano positions, he said that the positions moved as follows: 1. The positions originally were in a BS combined marketmaker account. This account held the positions of all BS market-makers but the positions could be identified by account. 2. OCC received instructions to transfer about 20 different accounts in BS combined market-maker account to a BS market-maker account where the accounts could not be separately identified. The people at OCC who perform this function would not know which accounts were being transferred unless they checked the acronym. 3. Several days later, OCC received instructions from BS to transfer the accounts from the BS market-maker account to a BS proprietary account. He said that he had the information as to how BS closed the Pompano positions. It took some time for OCC to track what happened once the positions were transferred out of the first account. In the first account, the Pompano positions were separately identified. After the transfer, OCC personnel had to trace what occurred. Mr. Dengel said he considered it part of the second step of the negotiations for him to tell us what happened to the positions. I asked him who was overseeing the market going to hell and what did they know about the Pompano situation. He said that the CBOE was not the DEA for BS and therefore was not monitoring BS's capital during the crash. It was too busy trying to keep up with those it was responsible for. Mr. Dengel said that he talked to the CBOE financial compliance office which said that he had had no contact with BS during the week of 10/19 to 26. He said that the CBOE reviews the transactions of its members. This review is done through a "focus report". This is a historical review and was the lowest priority during the crisis. The CBOE will, review whether a member traded while in deficit which is against the rules. But this review will be made long after the fact.
,T ,,, N-17-10
-4He said no one at CBOE was dealing with the Pompano situation during the crisis. They learned of the Pompano close out in the papers. They also were not following BS problems with its other market-makers. Mr. Den el said that CBOE and 0CC were willin•to re resent yRp_zomethsact,ts?nthatBStooL thatthedidnotar cinta}g cinthe nawcsojrlts1.dnotrati Por nataryti neafter l the fact. He said that b exercisin•instructions from BS 0CC
dial not approve or ratifK BS' actions.
On the issue of arbitration, CBOE says that Sec. 18.1(d) is not a substantive provision. It reserves the members right to proceed in federal court if the member otherwise has the right to proceed in federal court.
By virtue of being a CBOE member, Pompano did not waive its rights to proceed in federal court for securities law claims.
I told Mr. Dengel that we would analyze what he had said and get back to him.
cc: Steve Lawrence Roger Colaizzi
STATEMENT BY THE OPTIONS cLzARTNG conrommIN ' AND ciacAao BDA ,D OPTIONS EXCHAN04,'INC.
Pompano-Windy City Partnere, Ltd. ("Pompe6") was a 14 market maker pursuant to Emc Rula 1503‘.1(a)(6),' 17 CFR 1240.150.1006), and cleared through The Optioni s Clearing Corporation ("OCC") Clearing Member Bear Stearns. I Secause of Pompano's market maker status, its potations were identifiable at 0CC by the ACronyms of Pompano's traders. Pompailo"s' . option oontraots were maintained by Boar Stearns, under the .acronyms of Pompano's traders, at OCC in a combined market makers' account pursuant to OCC By-Laws, Article VI, Section 3(c). 2. OCC has determined that no tradesli offsei or closed out the options petitions, that were in the Pompano aocoUnts on October, 23, 1987. 6 4. . The rules and by-laws of 0CC and ME prov;.deifor the assignment of exercise. notices for index options, including the type traded by Pompano. In accordance with those roes and bylawss, exorcize rioticep may be assigned to market MakOra who lire writers of listed options. A market maker options Writer only becomes obligltod pursuant to an exercise assignmiant in the following wayt -,
a. occ assigns an exorcise notice to !a Clearing Member by the market maker's acronym in respect o the short positions maintained in the Clearing Member's combined market makere 0 account; and
b, Upon receiving notice of the assignment, the Clearing Member settles directly with OCC in respoct of the assigned options Contract) and
el The Clearing Member both notifies t$e assigned market maker of the assignment and settles directly with the market maker, making the appropriate adjustments to' the market maker's account taintaited at the Clearing Member.
4, CCC has determined that there wore no ass 11. gnments of exercise notices to the Pompano acronyms subsequent to the close of business on October 22, 1987. c5OE (as it pertains to trades The term "trade" means a transaction for value.
The applicable 000 and CO rules, by - laws, arid; procedures BZ specify the technical procedures for the easignment bt exercise notices. The steps enumerated describe the general proCodure under OCC
- 2 on Ca0E) and CDC have also determined that no tradOs occurred through the Pompano acronyms subsequent to the close of business
on October 22o 1087. :4, 4.04,/ f ino options AfligligarpiAm4 posithne were carried in the hear stearne combined Market maker account with OCC under the Pompano acronyms, and Ocp therefore could not have assicrned exercise notices to that Bear Stearns account Under the Pompano acronyms.
O. Atter the expiration date options betome valueless. If attar the expiration date, the market maker options 'writer has not become obligated by assignment of an exercise notice as described in 13 above, the market maker options wrIter cannot
thereafter become so obligated,
Dated February 28, X989
yt anoy R. Crossman First Vice.-President and
General counsel Chicego Board options Exchange, Inc.
By Don L. Horn to senior Vice-Preside General counsel
The Options Clearing
17:=4 FROM COLE CORETTE
Home Address 11 Island Avenue Apt. #1204 Miami Beach, FL
Senior Vice President - Drexel Burnham Lambert, Inc. Founding Director - Chicago Board Options Exchange Chairman - Chicago Board Options Exchange (1973 - 1976) Founder and President - Options Division Sedurities Industry Association Founding Chairman - National Association of Securities Dealers National Option Committee Creator of options Course - New York Institute of Finance Pomerance Prize - created by the Chicago Board Options Exchange in his honor - a cash award is given annually to a graduate student doing original research in options. Arbitration Panel - New York Stock Exchange and National Association of Securities Dealers 1982 was Mr. Pomerance's 50th year on Wall Street Retired March 1, 1988
NOV-3U-1990 17: 35 FROM COLE CORETTE ABRLITYN
The Pomefohoe Prize for Excellence in the Area of Options Resedfch was established Decemoe. 1976 in reco9nIton of Leon Porheronce's irnfreosuroble COntribUtiOn tO t*. creation and development of the Chicago Soora Options Exchange. One of the wolbs foremost outhorities on 00, 10r5 S. Mt POrneOnCe served since Peon1drv.1472 on the fOundihg Bacro of Directors ono from jonvoty,1474 to December. 1Q76 as itS ChaInnon
An Qwaro of S1. J) in cash will be given onnuo!ly ay the Choopo Board Options Excnonde
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