John Lothian Newsletter: Deutsche Boerse Said to Plan Elimination of 35 Managerial Jobs; LSE sells Russell Investments to TA Associates for $1.15bn; Bill Gross’s Lawsuit Against Pimco: A Look Inside

Oct 9, 2015

First Read

Fusion, Confusion & Illusion in the Stock Market | Ricky Cooper | TEDxIIT
TEDx Talks
People who patiently find everything they can about a company before purchasing it, buy from people who don’t know what the company they are selling actually does. Does this melding of different ideas lead to good outcomes for society, or just confusion?

**** We wanted IIT Stuart School of Business professor Rick Cooper to speak at our Summer Intern Education series in Chicago this summer, but he was out of town. He did however give a real TED Talk and here it is. It is worth a listen.


Focusing on Market Liquidity
David Krein, MarketAxess Research Blog
The growing swells of regulatory and market structure change have created an intense focus on credit market liquidity. When asked to share their current trading experience or their view of what’s to come, clients are rarely empty-handed yet always seek out new information and insight to complement (and occasionally challenge) their existing understanding..

***DA: Great post by Krein, perhaps my favorite speaker at this summer’s MarketsWiki Education New York series. If I understand him correctly, the liquidity problem is that the bond pie is growing more than the appetites of those at the table.


College Students Are Graduating Into an Incredible Job Market
Bloomberg, via Yahoo Finance
College students can look forward to another massive year in hiring, a new report shows. Employers said they expected to hire 15 percent more college graduates in the 2015-2016 academic year, according to a survey published on Thursday by Michigan State University.

***DA: This puts more pressure on our industry to showcase that which makes us special. That is the mission of MarketsWiki Education, which heads to London next week.


MarketsWiki Education London 2015

FIA Releases SEF Tracker Report for August
This issue shows average daily volume through August 2015 for interest rate, credit default and foreign exchange products traded on swap execution facilities. In the latest month, trading volume averaged $371.77 billion per day, down from $396.18 billion in July but up from $284.56 billion in August 2014. On a year-over-year basis, most of the increase came in the interest rate sector; trading of foreign exchange products was roughly the same and credit trading was lower in August than a year ago. This issue also contains an updated spreadsheet with weekly data on the total notional volume traded on SEFs.


Trib Tower for sale
By LYNNE MAREK, Crain’s Chicago Business
Tribune Media, the Chicago broadcast company that kept Tribune’s real estate when it split with Tribune Publishing last year, has put the company’s historic 36-story Tribune Tower on the sales block.

***** The new headquarters for John Lothian News? Our office would fit in their board room.


Hedgie buys $60M penthouse in wake of divorce settlement
By Jennifer Gould Keil, NY Post
Although big spending billionaire Ken Griffin has settled his ugly divorce battle with his wife of 11 years, Anne Dias-Griffin, his massive real estate spending spree is far from over. Griffin has just plunked down $60 million on an eight-bedroom penthouse duplex at Faena House in Florida, real estate sources tell The Post.

***** I hate it when I am right (See the 2nd story from the top in yesterday’s newsletter).


Rick Tomsic, Tradovate – Building with Vision

“You don’t need 20 years in an industry to have vision. Some of the best ideas come from a unique vantage point. Your vantage point… it’s not jaded. You don’t know how futures technology may be used. You may look at it from a fresh alternative.”

The first step down an unknown path takes guts. But if you’ve calculated your risks, you have a chance for outsized rewards. For Rick Tomsic, CEO of Tradovate, that step meant leaving an established position in a managerial program for an eat what you can kill broker gig. A step further down the road and Tomsic occupied a 12 foot by 12 foot office in a house sporting a gigantic satellite on its roof, sweating buckets due to the large monitors while working his 10 phone lines. But it was what he needed to do to fulfill his eventual goal of building trading technology. In this video, Tomsic imparts the need to maintain your drive by both having fun and maintaining your vision.

Watch the video at »

Deutsche Bank Lesson: Time for Banks to Go Goodwill Hunting; More banks need to follow the lead of Deutsche Bank and UBS in recognizing the cost of their old deal-making ways.
Time to ‘fess up. Banks pursued a lot of ambitious, empire-building deals in the glory days of the late 1990s and 2000s. It was the era of the universal bank and everyone wanted in, especially after the repeal of the Glass-Steagall Act in the U.S.


Lead Stories

Deutsche Boerse Said to Plan Elimination of 35 Managerial Jobs
John Detrixhe – Bloomberg
Deutsche Boerse AG is planning to shed 35 managers as its new chief executive officer implements his strategy for the market operator, according to two people with knowledge of the matter.

LSE sells Russell Investments to TA Associates for $1.15bn
Philip Stafford in London, FT
The London Stock Exchange Group is set to offload Russell Investments, an asset management business it inherited with the purchase of index compiler Frank Russell, for $1.15bn to private equity group TA Associates. The figure represents the lower end of what the market had expected.

Bill Gross’s Lawsuit Against Pimco: A Look Inside
A year apart from Pacific Investment Management Co. appears to have done little to ease Bill Gross’s feelings about the events that led to his acrimonious split from the firm.

Allianz says Bill Gross’s $200 mln lawsuit has no merit
German insurer Allianz on Thursday said a $200 million lawsuit launched by former employee and renowned bond investor Bill Gross over his ouster from Allianz’s asset management unit Pacific Investment Management Co (Pimco) had no merit.

New York trading firm to pay $1 mln to settle SEC charges over spoofing
A New York-based proprietary trading firm and one of its co-founders will pay more than $1 million to settle civil charges alleging they engaged in a manipulative trading strategy known as “spoofing,” U.S. regulators said Thursday.

Christine Lagarde open to second term as IMF chief
Shawn Donnan in Lima, FT
Christine Lagarde has opened the door to a second five-year term at the head of the International Monetary Fund, saying she is “prepared to serve” if the fund’s shareholders decide to keep her as managing director.

Global Worries Kept Fed From Hiking Rates in September
NY Times
Federal Reserve officials were almost ready to raise interest rates in September but held off because of China’s economic slowdown and its potential to derail U.S. growth and inflation.

Volatility as an asset class
Todd Hawthorne, Pensions & Investments
Over the past 36 months, the U.S. equity markets have displayed an almost zen-like ability to shrug off bad news, be it the turmoil in Greece or the collapse in energy prices; events that in other eras might have set Wall Street ablaze. This cocoon of contentment, however, was ripped open in late August, when observers of U.S. equity markets were offered a painful reminder of what volatility looks — and feels — like, as the Dow Jones industrial average suffered its largest ever three-day loss, attributable to worries over sustained economic weakness in China.

Gentlemen May Prefer Bonds, But More Traders Take Stocks; Revenue from bond trading on the decline, while stock trading picks up steam
Wall Street’s trading business is going through a profound change—and bonds are on the wrong side of it.

Clinton Proposes Big Bank ‘Risk Fee’; Proposal includes new taxes on certain trading and stiffer penalties
Hillary Clinton sought middle ground in one of the most contentious debates roiling Wall Street, proposing a new “risk fee” on large financial institutions dubbed “too big to fail,” but stopping short of demanding the breakup of such firms backed by populist critics.

Hillary Clinton tacks left with Wall St crackdown
Demetri Sevastopulo in Washington, FT
Hillary Clinton, the frontrunner for the Democratic presidential nomination, is set to propose a crackdown on Wall Street as she tried to fend off a challenge from her party’s leftwing.

Ponzi Suspect’s 17 Accounts Raise Questions Over Bank Safeguards
Neil Weinberg – Bloomberg
New accounts opened after Feds seized gold bars, Lamborghini
As one bank got wary, $1.8 million sent to Citibank, U.S. says
The U.S. requires banks to know their customers. Looks like several big ones, including Citigroup Inc., JPMorgan Chase & Co. and Wells Fargo & Co., may have missed getting acquainted with Daniel Fernandes Rojo Filho.


Mifir reporting rule ‘impossible’ to apply to OTC derivatives
The Trade News
Introducing new rules requiring derivatives participants to apply International Securities Identification Numbers (ISINs) to their OTC trades is ‘impossible’, according to an industry expert.

U.S. Chases Swiss Bank Secrets to Singapore and Israel; Dozens of banks signed amnesty agreements disclosing tactics, providing prosecutors with valuable information
David Voreacos, Giles Broom – Bloomberg
At a rate of one or two a week, Swiss banks are doing what was once unthinkable: revealing to the world how they helped wealthy Americans cheat on their taxes.

Flash Crash’ Fix Faces New Setback
A troubled market monitoring project launched after the 2010 “flash crash” has faced a new setback: regulators have failed to hire a technology expert to oversee development of a giant computer system to track the trading of stocks and options.

Advocacy groups want SEC chair out of vote for auditor watchdog
Fourteen advocacy groups have asked U.S. Securities and Exchange Commission Chair Mary Jo White to disqualify herself from selecting the government’s top audit regulatory official, saying she has a potential conflict of interest involving her husband.

Allen & Overy Partner Co-Authors Chapter on Swap Dealer Pay-to-Play Rule in 2015 Edition of Book on Regulation under Dodd-Frank | Allen & Overy LLP
The 2016 elections pose potentially significant set of compliance challenges for swap dealers subject to CFTC Rule 23.451, the pay-to-play rule established by the U.S

Sebi reviews trading capacity norms for exchanges and clearing corporations
The Securities and Exchange Board of India or Sebi, on Thursday reviewed the norms for the capacity of exchanges and their clearing corporations to handle trading work load and directed them to have an installed capacity of at least 1.5 times (1.5x) their projected peak load.

Futures commission merchants (FCMs) and retail foreign exchange dealers (RFEDs) must file monthly financial reports with the CFTC’s Division of Swap Dealer and Intermediary Oversight (DSIO) within 17 business days after the end of the month. Selected financial information from these reports is published below. The most recent month-end information generally is added within 12 business days after FCMs and RFEDs file their reports, but occasionally may be added later. For example: The 17th business day filing “due date” for February 28, 2015 financial reports was March 25, 2015. The 12 business day target for posting these data was April 10, 2015.

Exchanges & Trading Facilities

CME Group Announced Launch of South American Short-Dated New Crop Soybeans Options
CME Group, the world’s leading and most diverse derivatives marketplace, today announced the launch of Short-Dated New Crop options based on the May CBOT Soybean futures contract reflecting the South American harvest. These new contracts will expand the existing suite of Short-Dated New Crop options offered to customers and will be available for trading as of November 2, 2015, pending all relevant regulatory review periods.

Volatile market prompts CME Group to raise live cattle margins
CME Group Inc, the world’s largest livestock futures market operator, has raised margin rates for live cattle futures for the second week in a row after dramatic swings in the market, an exchange spokesman told Reuters on Thursday.

Boerse Stuttgart Launches New Exchange System, Xitaro, Powered by Nasdaq
Nasdaq (Nasdaq:NDAQ) and Boerse Stuttgart have officially announced that Boerse Stuttgart, Germany’s leading exchange for retail investors, has gone live on Genium INET. The system named Xitaro will be used for trading of all asset classes including equities, fixed income, exchange traded products and securitized derivatives. In addition to delivering the exchange system, Nasdaq is also providing Boerse Stuttgart with hosting and technical operations services.

Dubai’s DGCX to launch mini WTI crude oil futures, India Silver Quanto futures Oct 9
Hellenic Shipping News Worldwide
The UAE’s Dubai Gold and Commodities Exchange will roll out two new products, namely a mini-sized WTI futures contract and a India Silver Quanto futures contract, on Friday, the commodity derivatives bourse said.

Hedge Funds & Managed Futures

120,000 investors sign up for Lloyds share sale in just four days; Hargreaves Lansdown reveals that the sale of the Government’s remaining Lloyds stake had proved popular with clients
By Reuters
More than 120,000 investors have registered an interest in buying shares in Lloyds Banking Group with stockbroker Hargreaves Lansdown in the four days since the Government put its remaining £2bn stake up for sale.

Wall Street guru who has been nailing the interest-rate story just made a jarring prediction for 2016
Business Insider, via Yahoo Finance
HSBC’s Steven Major is out with a bold new forecast.

In a client note on Thursday titled “Yanking down the yields,” the interest-rates strategist projected that bond yields would be much lower than the markets expected because central banks including the Federal Reserve were reluctant to raise interest rates.

A BlackRock Salesman’s $2 Trillion Quest in the Land of No Yield
Yuji Nakamura, Nao Sano – Bloomberg
ETF sales to regional banks surge as BOJ caps bond returns
Lenders’ push into riskier assets has some analysts concerned
Pick a spot on a map of Japan, and odds are that BlackRock Inc.’s Riku Takewaki has been there this year.

Mexico puts yen bond sale on radar screen
Mexico has a possible yen bond sale on its “radar screen” as it looks to pre-fund for 2016, Alejandro Diaz, the country’s head of public credit, told IFR on Thursday.

Banks & Brokers

Goldman to release results on website, drops BusinessWire-source
Goldman Sachs Group Inc will not release its third-quarter earnings report next week through Warren Buffett’s BusinessWire, a person familiar with the matter said.

Deutsche Bank Said in Talks to Sell $250 Billion Swaps Book
Michelle Davis – Bloomberg
Transaction to help bank meet goal of shrinking balance sheet
Liquidity in market has declined on stricter bank regulation
Deutsche Bank AG is selling a credit-default-swaps trading portfolio of more than $250 billion, with JPMorgan Chase & Co. among several banks in talks, according to two people familiar with the matter.

JPMorgan Trader, ICAP Broker Helped Hayes Rig Libor, SFO Says
Bloomberg Business
A former trader at JPMorgan Chase & Co. hatched a plan with a broker at ICAP Plc to help Tom Hayes rig Libor by buttering up the U.S. bank’s new rate setter, according to recorded phone calls played to a London jury Thursday. Stuart Wiley in an August 2007 phone conversation with ICAP broker Danny Wilkinson openly discussed manipulating the benchmark, prosecutors at the U.K. Serious Fraud Office said. Hayes, the former UBS Group AG and Citigroup Inc. trader who was convicted of rigging the London interbank offered rate in August, was referred to by the nickname Choc Ice.

Clearing & Settlement

TriOptima and SwapClear eliminate 20% of interdealer notional outstanding in cleared Canadian Dollar interest rate swaps
Press Release
TriOptima announces today that 18 participants eliminated $1.6 trillion Canadian Dollar (CAD) in LCH.Clearnet’s SwapClear. This represents 20% of the interdealer CAD notional outstanding in CAD cleared interest rate swaps in the clearinghouse (CCP).
“Our last two cycles have eliminated $3.3 trillion CAD in outstanding CAD interest rate swaps in SwapClear , contributing to a further reduction in systemic risk for the market and regulatory capital for individual institutions,” said Michael Modlock, Head of triReduce North America.

A new dawn: client clearing
Futures & Options World
Next year the market is set to see the introduction of mandatory client clearing in Europe, after several false starts, but what effect will this have on relationships, and what does the future hold, post-mandate. Alice Attwood reports. Client clearing is coming, that much is indeed clear; the mandatory clearing of standardised over-the-counter (OTC) derivatives, along with margin for non-cleared trades, were key goals of the European Union’s post-financial crisis regulation, the European Markets Infrastructure Regulation (Emir).

Eurex Clearing launches new service for initial margin calculation
Deutsche Borse subsidiary Eurex Clearing, which is one of the world’s leading clearinghouses, is launching a new service for calculating initial margins on current and hypothetical portfolios. The new service, called Eurex Clearing Prisma Margin Estimator (PME), will become available November 16.

Deutsche Bank becomes a direct participating bank of China’s newly launched CIPS
Initiated by the People’s Bank of China (PBoC) and run by the CIPS Clearing Company, CIPS provides an independent cross-border payment and clearing system connecting both onshore and offshore clearing markets and participating banks. CIPS uses global payment standards and enables same day clearing across Asia, Oceania, Europe and other time zones through extended operating hours, according to Deutsche Bank

Banks must embrace fintech-fuelled payments revolution – BNY Mellon
Banks must embrace fintech companies or risk being left behind as the payments landscape undergoes a radical technological overhaul, according to a new report from BNY Mellon.

Indexes & Products

Meet The First New Sector SPDR ETFs In 17 Years
Two new Select Sector SPDR ETFs launched on the stock market today, marking the first addition to the well-loved suite in 17 years and taking its total to 11 index exchange traded funds. They give investors exposure to the financial services and real estate sectors. Select Sector SPDR ETFs track modified market-cap-weighted indexes of select S&P 500 companies.

U.S. Companies Continue To Slow Pace of Dividend Net Increases
S&P Dow Jones Indices announced today that the indicated dividend net increases (increases less decreases) rose $10.0 billion during the third quarter of 2015 for U.S. domestic common stocks, a deceleration from the $12.3 billion increase registered during the third quarter of 2014. The dollar amount decline equates to a 19.1% year-over-year slowdown in dividend increases. For the 12 months ending September 2015, dividend net increases fell 15.1% to $49.1 billion compared to an increase of $55.5 billion for the corresponding period.

Rosy outlook for smart beta ETFs, but investors require more education, reveals FTSE
ETF Strategy
FTSE Russell, a leading global index provider, has released the results of a survey of US-based investment advisors highlighting current perceptions and adoption levels of smart beta strategies in the community. The key takeaways from the survey point to a necessity for greater education amongst advisors with only 18% of respondents admitting to being “very familiar” with the strategies. Encouragingly, there is evidence of continued demand for smart beta products which will drive industry growth and support exchange-traded fund (ETF) providers who have embraced these strategies.

Why the S&P 500 Utilities Sector Shined in Q3
Indexology – S&P Dow Jones Indices
While the S&P 500 Utilities index has been one of the weakest in the S&P 500 index in 2015, in the third quarter it was a bright spot. As global economic concerns increased, we think investors found the domestic focused, stable dividend, and earnings provided by the sector appealing. While the Federal Reserve’s possible increase in the Fed funds rate could have an adverse effect, the 10-year Treasury yield has fallen back to approximately 2.0%. The average dividend for the S&P 500 utilities sector constituent was 3.9%.


A leap of faith? How to make it in Fintech
f the career switches of prominent Fintech CEOs are believed, there’s a fairly simple equation to getting into the sector – quit your banking job, use your own savings to get the new business off the ground. Sit back and let the seed money flow in. And yet, moving across to an inherently risky sector where inevitably some firms will fall by the wayside or be consumed by a larger rival is something of a leap of faith. What’s the best approach for launching a Fintech career? Should you gain financial services experience initially and then gravitate across, or launch straight into Fintech? This is what prominent start-up CEOs advise.

Barchart Releases Version 3.0 of the App—Expanding Access to Stocks, ETFs, Options, Forex, Futures and Commodities
Today,, Inc., a leading provider of market data and information, has announced the release of version 3.0 to the mobile app which provides free access to stocks, ETFs, options, forex, futures and commodities market data and information. The app, which is available on all iOS and Android mobile devices, provides users with extensive market data and news coverage along with charts, screeners, portfolios, trading strategies, financial statement data, technical analysis and more. With the new release, app users will gain an enhanced experience to stay-on-top of the financial markets through faster in-app speed, additional fundamental stock data, price and news alerts, and more.

Apple has removed some apps from the online store over concerns they put users’ personal data at risk
Apple Inc said on Thursday that it had removed “a few” applications from its App Store, expressing its concern that the security of some users’ personal data could be compromised in certain circumstances.

Dell seeks $40bn in financing to buy EMC
James Fontanella-Khan in New York and Richard Waters in San Francisco, FT
Dell is in talks with banks to line up $40bn in financing for an acquisition of storage company EMC, according to people familiar the matter, marking what could become the tech industry’s biggest-ever acquisition.

5 Mistakes You Should Avoid When Starting A FinTech Company: Lessons From A FinTech CEO
Starting a bitcoin exchange has been a crash course on how banks operate that touches upon every aspect of that business – especially regulation. When I was in investment banking, my peers and I joked that we had no marketable skills outside of the bank. Times have changed, and there has never been a better time for someone in the financial services industry to become an entrepreneur. It could be you!


SEC Charges Firm and Owner With Manipulative Trading
An SEC investigation found that Briargate Trading LLP and co-founder Eric Oscher orchestrated a scheme in which they placed sham orders — spoofs — to create the false appearance of interest in stocks and manipulate their prices. After entering spoof orders, Oscher placed bona fide orders on the opposite side of the market for the same stocks and took advantage of the artificially inflated or depressed prices. Immediately after the bona fide orders were executed, Oscher canceled the spoof orders.

Wolverine Affiliates Charged With Failing to Maintain Policies to Prevent Misuse of Material Nonpublic Information
The Securities and Exchange Commission today charged Wolverine Trading LLC and Wolverine Asset Management LLC with failing to maintain and enforce policies and procedures to prevent the misuse of material nonpublic information. The Chicago-based affiliates will pay more than $1 million to settle the SEC’s charges. Each agreed to pay penalties of $375,000, and Wolverine Asset Management will pay disgorgement of $364,145.80, plus prejudgment interest of $39,158.47.

Ex-Deutsche Bank trader pleads guilty in U.S. to Libor scheme
By Nate Raymond, Reuters
A former senior trader at Deutsche Bank AG pleaded guilty on Thursday to engaging in a scheme to manipulate Libor, the benchmark interest rate at the center of global investigations involving various banks, the U.S. Justice Department said.

Environmental & Energy

Global warming is shrinking California’s critical snowpack; Rising temperatures are melting the Sierra Nevada snowpack
John Abraham, The Guardian
As the world warms, it leads to very obvious results such as a reduction in snowpack in various parts of the world. While this seems intuitive, there are some caveats. A warmer world is also a wetter world because there is more moisture in the air. Therefore, there is a potential for more snow.

Now ‘right moment’ for carbon tax – IMF chief (News | National)
The Namibian –
The time is right for governments to introduce taxes on carbon emissions, which would help fight global warming and raise badly needed revenue, IMF chief Christine Lagarde said Wednesday.

May says Canada’s 2020 emission-reduction targets out of reach
The Globe and Mail
The Conservatives’ target to reduce carbon emissions in Canada is out of reach because the Harper government failed to enact any measures to achieve them, but a new government would almost certainly be more aggressive, Green Party Leader Elizabeth May said on Thursday.

Climate Scientist Faces Backlash for Urging Investigation of Fossil Fuel Companies
By Katherine Bagley – InsideClimate News
A climate scientist who was the lead signatory on a letter urging President Obama to launch a federal investigation into whether fossil fuel companies “knowingly deceived the American people about the risks of climate change” is now facing an investigation by Congress because of his part in the letter.

1st “Carbon Efficient” Financial Index Launched On Shanghai Stock Exchange
The new index — the Shanghai Stock Exchange (SSE) 180 Carbon Efficient Index — was launched jointly by the SSE and China Securities Index, and will reportedly only be comprised of “low-carbon” companies that outperform (or match) their market.


20 photos that show how insanely crowded China has become
Jack Sommer, Business Insider
China’s population was approaching 1 billion when it enforced a one-child-per-family policy in the late 1970s. Exceptions were only made in the cases of ethnic minorities and rural couples, who were sometimes allowed two children.

Singapore’s hazy future funk
Asia Times
Singapore shares were down 20% on the MSCI Index through September as the economy tipped into quarterly recession and the area wildfire haze threatened a further blow to construction, tourism and retail sales which had offset lagging exports to China.

If you thought China’s equity bubble was scary, check out bonds
The Economic Times
As a rout in this year erased $5 trillion of value, investors fled for safety in the nation’s red-hot corporate bond market. They may have just moved from one bubble to another.

Rich Chinese Can Have In-Home IMAX Theater Systems for $400,000
Frederik Balfour – Bloomberg
Includes screens 20 feet wide, 10 feet high and sound system
CEO Gelfond targets movie-lovers who live in mansions
IMAX China Holding Inc., which made its stock-market debut in Hong Kong this week, is launching an in-home entertainment system targeting wealthy Chinese who would rather stay home to watch movies. The cost: a mere $400,000.

China’s Heft Gives It Ammunition Against the Trans-Pacific Partnership Trade Deal
China’s huge domestic market, deep supply chain and push to create more consumers at home gives it heft to dispel challenges of the new Pacific trade pact that it isn’t a party to.

Frontier Markets

NSEL Scam: Brokers may get away scot-free as SEBI too is not interested in probe
Mahesh S Bhatt, R Balakrishnan, Moneylife
Minutes of one of the last FMC meetings note rampant client code modifications by NSEL brokers “who may have indulged in manipulation in order to evade taxes, which needs to be probed into”

BSE fines 370 firms for not having women director
Sebi had issued guidelines in February last year asking companies to appoint at least one woman director on their boards by 1 October, 2014

Long-Term View is Murky for Turkey
ETF Trends
The iShares MSCI Turkey ETF (NYSEArca: TUR) has been one of the most embattled single-country emerging markets exchange traded funds thanks in large part to a tumbling lira and speculation that Turkish equities are among the developing world’s most vulnerable to hawkish changes in Federal Reserve interest rate policy.

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