Rich Ilczyszyn: Inside MF Global During Its Collapse
What was MF Global? What kind of business did it do?
In the last couple years, MF was trying to be an investment bank. ED & F Man, where the company started back in the 1800s I believe, was a commodities firm. It became an FCM, which is a futures clearing merchant. And toward the end, [CEO] Jon Corzine tried to take the company to an investment banking business.
You came there when?
I came in 2005 when we were with another company. I started my career in this business in the retail brokerage end with Lind-Waldock. Lind-Waldock was acquired by a company called Refco. Refco had problems, went out of business. ED & F Man bought Refco, kept the Lind-Waldock name as the retail division or retail brand. ED & F Man spun off a couple of divisions and became, in the last couple of years, MF Global.
And what kind of place was it to work?
Initially Lind-Waldock was a great company to work with. People had been there for years, solid people and good work environment. But toward the end of MF Global, the sentiment changed, and certainly the feeling in the company soured a bit as the company wasn’t doing so well. …
What was [MF Global] known for the on the street? What was its reputation?
… My experience in our division, Lind-Waldock, the retail division of futures for MF Global, was airtight. Compliance was what I’d consider above and beyond. … The company mantra, if you will, was “Go above and beyond compliance,” so that way you have no problems, … and you keep your customers forever.
I’ve heard people talk about MF Global as having a lot of problems and having horrendous controls on its bookkeeping.
… From my experience, we really didn’t have that issue. Our division was run as a separate entity just until the last couple of months. Lind-Waldock was part of MF Global. Toward the end, … we changed the name from Lind-Waldock to MF Global Futures.
Was there a difference in cultures?
I think the culture changed when they started changing compensation packages for brokers or producers like myself, who had contracts. And then they changed the contracts midstream. … You know, the stock’s trading at, like, 8 bucks, and then it’s at 6 bucks, and then all the producers get whacked with a different compensation package.
For me, that was the opening of my eyes, going, “Well, you know, if they’re squeezing out their producers, taxing them, if you will, and forcing them to buy stock instead of giving them cash incentives, they’re trying to keep the stock price up.” So whoever is running the company is more worried about the stock price than they are the employees, or maybe that type of business.
There was also, toward the end, the kind of a feeling that MF Global as a company didn’t get what we do in the futures or commodities space. They didn’t get it. So the direction started going to investment banking, and for me that was a wake-up call again, too.
Those were the two things that I really keyed off of, the compensation change and then the corporate culture of going into investment banking, which really doesn’t make a lot of sense with commodities and futures. It’s a whole different world.
When were you approached and told that your compensation was going to change?
I can’t remember. It must have been two years ago, sometime in 2010. And it was postdated, which was another insult. Let’s say it was 2010, the end of January, February: “We’re changing your compensation package made effective 30 days ago. Take it or leave it.”
That was a red flag for you that there was trouble at the company?
Yeah, absolutely. …
Were you aware that MF Global as a whole entity was losing money?
Not specifically. But it just felt like if they’re squeezing the producers and they’re laying people off, that’s not a growing phase, right? That’s a typical Wall Street, “We’re going to cut employees, and then we’re going to squeeze their compensation to make the company more profitable.”
… It was just after your compensation was changed that Jon Corzine took over.
What was the sense inside the company when you heard that Jon Corzine was going to be the new CEO?
Well, initially I thought it was great. The stock price jumped. And it was Corzine on paper. It was a dynamic character, … from the military to Goldman Sachs to [New Jersey] governor. …
And especially with the climate with regulation and everything, my first inclination was, “That’s great; he’s going to have political connections; this is going to be great for the company,” you know. So I was sipping the Kool-Aid at that time. …
… What were the other traders saying?
We’re all saying the same thing, “You know, this is going to be great,” because there could be some dynamic growth. …
When was the first time that you met Jon Corzine?
… It was at a company session where you did a walkthrough. And I just got a sense of the guy just hearing him speak. …
And how did he strike you?
I was expecting [a] Gen. Patton type of character, and he wasn’t that. I was really expecting a charismatic leader, and I just didn’t get that sense.
He was not very forceful as a personality?
Well, yeah, maybe that was just my meeting with him. And again, it wasn’t just a one-on-one with him.
… Besides the expansion into equities and forex [foreign exchange] and other forms of trading and other forms of brokerage, were you aware of other changes that were taking place in the culture of the workplace and the company?
… When [Corzine] came in, when the company was public, when it was all about equity price, our division in commodities was so highly regulated. We had an issue not in our division, at an IB [Introducing Broker] — and I can’t remember the time on that — there was a fat-finger error. Somebody had done some trade, and then they tried to back it out. It was an error, and it was a very costly [one].
This was in the wheat business?
In the wheat business. After that, it was just amazing the regulation that we had to go through. If I placed an order, it went through two or three different people before it was reviewed, it was executed. And then it was reported back. Then there was a whole line to ensure that no funny business would happen again. So that was a big change for us, you know. It was a good change, though.
… The company is also starting to make bets later in 2010 on European debt. Would you have been aware of that, sitting where you were in the company?
Was anything about prop [proprietary] trading known to traders like yourselves inside the company?
Were you aware that the company was doing prop trading?
Not at all?
I would assume that they were. I didn’t investigate. But if somebody’s trying to create an investment bank, that’s what they’d do. …
Right. But then there’s nothing unusual about that, as you said?
No, absolutely not. It’s actually a very profitable part of these companies. Goldman Sachs legendarily propped us. Yeah, absolutely.
Right, because what you guys generate basically are fees.
But they’re actually making highly leveraged trades. They can make big money.
When was the next time there was any kind of red flag that went up for you?
For me, it was the company was going in a direction that was anti-futures commodities, which I’ve devoted my life to. I felt like the future of what I did there was probably limited, because then we couldn’t get the stocks; we couldn’t get the forex. All those things that I thought we were going to get early on, we found out that they were going to keep these divisions separate. …
So we get the compensation cut, forced to buy stock. Then we get none of the perks of going into other avenues of business to get more clients. All that together, and then the share price was low — so all those things were the writing on the wall.
Then to see the management team at MF as a group of guys that had been very successful at different times not getting exactly what it is that we do now and how to move it forward, and I felt like, at some point, I could probably do this better myself.
The compensation change, … it would be a cut in your salary.
Twenty percent cut in your salary?
Any investment book you’ve ever read anywhere will tell you don’t invest 20 percent of your risk capital in the company you work for. That doesn’t make any sense, working at a company you [are fully vested] in, you know. And my thing is this: If it is such a dynamic, good deal, then let me buy it if I want it. And don’t make it retroactive 30 days and tell me I don’t have a choice. …
And unlike a paycheck that you can take to the bank, you’re getting stock, which can go down in value.
Oh, yeah. It’s called a “golden handcuffs” [package], and [it] is a quarterly buying [of] a stock that you essentially never get out of.
So that’s a sign that the company is having trouble with its cash.
Yeah. What quicker way to raise cash than to cut the compensation? …
… How worried were you that MF Global might get into big trouble and that it might collapse?
I could never see the end result of this in a million years. And the last few years in the financial industry has just been one catastrophe [after another], you know, and you think, well, OK, that’s it; that’s the worst-case scenario. And then something else like this happens.
It’s just unbelievable to me. In this business, we’ve hung our hat on segregated funds for clients. We’ve hung our hat on that because that’s what has been our understanding of this whole relationship since I’ve been doing business 20 years. …
Tell me what you mean when you say “segregated funds for clients.”
If I’ve got a customer who has funds, those are their funds, period; that’s used for their trading. And if it’s not, it’s held in a segregated account with their name on it. So the idea that when a company goes under, that’s somehow lumped into company assets or tradable assets was a shock to everybody.
Has it ever happened before?
To my knowledge, it’s never happened before. And that’s another thing that … I always thought about, is that this has never happened. And I’ve been through the Refco thing. So initially when things started getting shaky, to answer your question, … sure, I was worried.
I’ve got a family, kids and a house and everything else. But we’d been through it before, and it was simply a name change. What happens is the company is still a viable company. There’s all the employees, the assets and the money in segregated accounts. Somebody else buys it out and just rebrands it and keeps on going.
Were you aware that a company by law was able to trade segregated assets in its proprietary account if it wished to in certain kinds of safe securities deemed safe?
Deemed safe securities, yes, and Treasuries and sovereign debt.
So would you tell your clients that their money might be used to buy U.S. Treasuries or even sovereign debt?
No, because actually, to be honest with you, when this whole thing unwound is when we started looking at all the extreme details here. But it’s been an industry standard that everybody knows. You’re in [segregated] accounts; that’s it. And I still feel confident that this thing is going to get rectified in some way. I really do.
… So I place my account with you, and that money goes in different directions. Explain how that works.
If you open up an account, let’s say you have $10,000 or whatever it is, and you buy a contract. There’s a margin that’s held by the FCM [Futures Commission Merchant] through the CME [Group]. It’s a good-faith deposit, if you will, to buy or sell that contract. The balance of your cash is held in a segregated account for you. That’s always been the industry understanding.
But it can be used.
Yeah, that’s where we’re at now, but for the last 20 years, we’ve never had a situation like this, ever.
But you’re saying that you were aware that it could be used by the firm for certain kinds of proprietary trades.
I have to be honest with you. Twenty years ago I didn’t know that. Ten years ago I didn’t know that. Two years ago I didn’t know that. Now it’s a term called “rehypothecation,” I believe, and … now we know.
Listen, if you put $1,000 or X amount of dollars in your bank, it doesn’t just sit there with your name on it. It goes. And if there’s a run on the bank, if everybody go gets [sic] their money at once, it’s not all going to be there.
So I think that you’ve got a combination of things at MF that happen: This trade, the share price drops, makes new lows; money starts to leave the firm all at once; they can’t meet the margin call; they can’t meet all the customer funds going out. There’s the problem.
The difference in a bank is that the FDIC [Federal Deposit Insurance Corp.] insures the accounts up to $250,000 now.
But there’s no such insurance for a client at a commodity brokerage.
Not now. I’m sure there will be after this mess. …
… So 20 years ago you didn’t know it; 10, two years ago you didn’t know that the money in the segregated accounts could be used to do prop trading. Did others?
I wonder, do we know that that’s what happened? Is it prop trading? …
Well, I know from the CFTC [Commodity Futures Trading Commission] that it can be done. I’ve looked into that.
Well, if the company takes that money and uses it to buy Treasuries or sovereign debt, that’s prop trading, isn’t it?
We’d have to talk to a lawyer. I’m not exactly sure if that would be considered prop trading.
Well, it’s done in order to make money for the company. It’s not going directly back to the client.
I guess when I think about prop trading, I think about a prop desk who’s using company money, not customer money, to trade. That’s the first thing that comes to my mind, … because I’ve been a prop trader, and the thing is you would use company’s money, not client funds for that. That’s the difference.
So perhaps it’s not called prop trading, but they can use it to make money for the firm.
Right. Listen, if Corzine was doing it with MF, I’ve got to believe that JPMorgan, Goldman Sachs are. It’s got to be the same type of industry standard, I suppose.
… As things were unraveling, or even immediately after Oct. 30, , when you knew that there was going to be no MF Global, when you talked to the other traders, was anybody aware that client money —
No, absolutely not. And I’ll tell you what: Being through the Refco thing — and there was fraud there — it was more the sense of this can’t be happening again, one; two, we’re going to get through this. And then the Monday after that, I think it was the 30th or 31st, we came in, and we couldn’t get out of trades.
There was no trading, could not get in or out. Then it was a completely different animal and just so unfortunate for clients. At that point, for me it was, “I know that I don’t have a job at MF; I’m going to stay here as long as I can to help facilitate my clients in the best way that I can, period.”
But I knew. I told my wife. … Then the stories were leaking. And then, you know, it was a trade, customer funds missing. And then there was a deal that was supposed to go through that weekend — I can’t think of the date — with Interactive [Brokers]. They were going to buy the company, change the name, and business would be operating as usual. And then there’s the whole shortfall.
… Put us there on Oct. 31, Halloween morning. You roll into the office pretty early.
It was unbelievable. It was something out of a movie. We get to the desk. You’re ready for the trade day, waiting to hear the news that perhaps we’ve been bought, and there was speculation that it was Interactive.
And again, I’d been through this before, you know, looking for probably the new owners to walk through the office and check out the place and all that. And the manager frantically came out of the office, said: “There’s no orders. No orders out, no orders in.” …
I said, “It’s got to be a mistake.” I mean, what are you talking about? … We’re talking about commodities, highly leveraged products that you’re in — oil, gold, gasoline — things like that that have volatile swings that you can’t get out of the market.
In other words, you had to tell your clients that had contracts on volatile commodities that they couldn’t get out of them even if they wanted to?
It was unbelievable. I just couldn’t even believe it. So we tried calling New York ourselves, and the phone was just busy. So the managers were trying. Couldn’t get anybody on the phone. And that was it. …
How long are you sitting there without knowledge of what’s going on? …
Too long. … We kind of all just — it was every man for himself. So I immediately got on the phone with all the clients, and we found [out] 15, 20 minutes later that you could in fact get out, but there’s only one phone number you could call for the whole firm, going through one order desk, and they were going to execute our business. They were doing us a favor. I can’t remember if it was another firm or if it was the division of MF that was taking those orders.
So that’s the one lifeline.
That was the one lifeline, and there were stacks of orders. And my thought was for all of our clients, let’s just get flat; get out of the market; reduce your risk until we know was the heck is going on.
So it was all hands on deck, and we started firing the orders. Then we didn’t [know] if we were filled or not at what price. For us it was … let’s get through this, cut the risk till we know what’s happening.
So you’re getting all your clients into cash as fast as you can?
But what’s happening to the value of the commodities that you’re selling, because it’s coming in fast and furious?
Some cases guys made money. The market moved their way. Some on the other side, some people lost money.
So it wasn’t enough [to] take the market down?
… I know that the market is still reeling from the loss of capital in the commodities because of the MF thing, so sure. The market probably could have moved one way or another based on that scenario, absolutely.
How much of the market was traded through MF Global?
I think they had a pretty darn good share. And again, they were the largest non-bank brokerage, to my understanding, out there, outside of Goldman and JPMorgan and all that.
… Meanwhile, what kind of rumors were flying around as to what the heck was going on?
Then there was the rumor — I think CNBC or somebody was breaking a story — that in fact customer funds might be the issue. That’s why the Interactive deal didn’t work.
What did you think then?
Can’t be true. … This has never happened before. It’s ridiculous. What do you mean customer funds are missing? I said, “How could it happen?” You’ve got the CFTC; you’ve got the CME.
These are the regulators?
Yes, and then you’ve got all of our compliance. I’m telling you, in order for me to place a five-lot contract of oil, which is relatively small in the scheme of things, they would go to me. Somebody else would see it. The orders would come back, they’re matched up, and everything is by the book. Does he have enough money to put the position on?
It was so detail-oriented. To imagine customer funds — and then they were saying it was $500 million; then it was a billion. It was just unbelievable. It was like a movie. And just how could it possibly be? …
As this is coming down, what are people starting to say? …
Customers were frantic. First of all, you know, my reputation’s on the line, right? I’ve done this for 15 years — stellar record, never any problems, that kind of thing. And now people are going: “What’s going on? You don’t have any information?” So I leaned on the company managers. We got nowhere. Nobody knew anything. So it was literally just a minute-by-minute situation.
I imagine the language was getting a little rough?
Oh, yeah. We’ll keep it PG here, folks, absolutely.
And then it changed. So then it was, “You can offset orders,” and then they pulled the phone number because there was an issue with the clearing. So then we had no way out. Then it came back on. I mean, it was chaos. …
When do you settle on the idea that in fact the reports coming over the TV are correct and that customer money is missing and this company is in big trouble?
I knew the company was in trouble a week before. Week before we [had] earnings coming up. They scooted up a day. And I’m thinking to myself, why would they have earnings, scoot it up a day? There’s got to be an issue.
You don’t just have an earnings day and then put it a day early. Earnings were dismal. Share price trades from X start to drop. Customers are calling: “Hey, you’re trading around 2 bucks. Should I be worried?” …
Customers are upset.
Yes. “Give me my money.” I said: “Great. We’ll send you your money. Let’s get you your money. Touch it. Feel it. Let’s get through this, and then we’ll get back into business.” I totally understand and respect that. Write out the requests, boom. Put ’em in, put ’em in, put ’em in. …
I think the earnings came out on Tuesday or Wednesday. By Thursday the stock was dropping, broke the 52-week low. New lows. Then it was at a dollar, and coming into that Friday, so we were just sending money out normally.
I don’t know what the percentage is, but equity going out is, you know, it’s not a big stack. But it was a big stack, so all that money was Niagara Falls going through a garden hose, right? All this money is trying to get out.
Call up customers on Friday night. There’s rumors that we’re going to have a buyout. This is a good thing for us. The company that’s supposed to be buying us, it’s going to be more technology, which is something that I want for my customers anyway. It’s scary, I know, but we’re going to get through this. This one we had no idea of customer funds being gone. Or it wasn’t even on the radar at that point, right, because —
It was beyond your imagination.
Exactly. So we come in. Code red on that Monday. And then we found out that half or more of those wires on Friday never got sent out. I’m like: “Well, where’s the money then? … What do you mean? They were in there. They were processed. They were actually physically processed. Where did the money go?”
Nobody had an answer. So then, you know, now customers are really terrified, and I’m terrified, too, for them.
Because they’re calling you up and saying, “Where’s my money?” And you say, “I wired it on Friday.”
“I put it in Friday. Let me get to the bottom of this. We’ll call you right back. We’re going to find this. We’re going to get through this.”
And then it started getting worse. And then that was when we see all the CNBC reports that perhaps customer funds were commingled, or whatever they were saying at that time.
You can’t be feeling very good about talking to your clients about it.
No, it’s terrible. Terrible situation.
When’s the next time you see Corzine?
You see him on TV?
… No, actually, I don’t think we do. I think he’s MIA. And in fact, we’re all waiting for a statement. My first thought was, there’s no customer funds missing; we’re going to get to the bottom of this, Patton leading the way. …
You got no phone call or no email announcement, memo?
… None of that. …
A few days later Corzine resigns.
Tries to, and I don’t know that he does. I think he tried to.
They stop it?
I thought they did. … Right after the share price broke, a buck or whatever it was, he tried to resign. They said, “You can’t.” And then perhaps that was the week after that he did.
[Editors’ Note: Jon Corzine resigned as CEO of MF Global on Nov. 4, 2011.]
When you place a trade for a customer, the counterparty is recorded, correct?
So money just doesn’t go into limbo. It goes and attaches itself to a counterparty?
And we’re talking about a billion dollars, and we can’t find it?
You can’t find it the first day. Can’t find it the second day. Can’t find it the third day. Are you kidding me? I one time inadvertently sent money from one account to another account. Missed a digit, you know, and it was immediately found. It took two or three days to get it. …
In December, Corzine is called to Capitol Hill to testify before the House Agriculture Committee. Did you watch?
I watched a little bit. I did see the apology, and I felt like he was sincere. …
You felt that he was sincere in saying what?
Well, he apologized for if there was anything wrong done, he was at the helm, and that was my understanding. …
What do you take away from this? What happened to the money?
I don’t know. My question is where the heck is the CFTC? Where is the fiduciary responsibility of all these, like I’m saying? Like I couldn’t send out a wire for one of my clients that five people didn’t touch.
So if you’re my client, you call me up and say, “Hey, listen, send me X amount of dollars,” I write up the request. It goes to one person. They check. They check the equity. Double-check. It goes to the next person. Double-check. And then the third or fourth person is the person who inputs. So perhaps things were a little bit different at the top. I mean, I don’t know.
Did you consider the business that you were in well regulated?
I did. I just know from my personal experience, the thing that we know from [Bernie] Madoff and all that, there’s going to be bad apples, right? I mean, things do happen because of the nature of human beings.
But I’ve always conducted myself in a way that I wouldn’t have to worry about that. What kills me about all these situations is, how can it possibly be worth it?
How do you sleep?
How do you sleep? … So the company doesn’t do well and you’re a CEO and you get canned, you know?
But Corzine, when he appeared before the House committee investigating all of this, seemed to you to be genuine?
Yeah. Listen, I’ve got to take a line from [CNBC’s Jim] Cramer. … He said, “Why would he take this job?”
Here’s a guy that’s had all this success, and he’s at a place in his life where maybe he doesn’t need to work or whatever. Why would he take this job when it’s such a difficult time to be an investment bank?
Interest rates are artificially low. This is why these companies perhaps go into these situations, to keep the stock price up.
In other words, they take greater risk because they can’t make money in Treasuries?
Because the interest rates are —
Near zero. … I also think it’s a symptom of Wall Street; I really do. I think it doesn’t matter about the employees. I mean, so many good people got canned; so many customers were affected.
It was all about the stock price that drove a lot of these moves in the market. So if Corzine’s trying to keep the stock price up, he’s trying to keep the shareholders happy, his big investors, and that’s the number one thing that they look for.
You said you were aware of Corzine’s political connections?
Yeah, ex-governor of Jersey.
Also he was well connected into the White House?
Well, listen, he was supposed to be number two behind, you know, for Treasury secretary.
When did you learn that?
That was kind of funny. I don’t remember exactly when, but we heard through the chatter in the office, at the water cooler if you will, that perhaps he may be leaving and pursuing his political career again.
Leaving to go where?
To the White House.
To go join the administration?
So you heard that somewhere in the summer of 2011 —
— that your CEO may be going off to be Treasury secretary?
Right. I think Corzine came out and denied that. White House didn’t make a comment.
But he was on the short list, in any case?
And that news had percolated down to you guys?
What did you think of that?
I thought, well, OK, so the guy comes into a CEO spot, makes all these changes, then leaves midstream. I thought that would be terrible for the company.
But you can’t be too happy with the company. I mean, the company hasn’t sort of fulfilled the promise.
April of 2011, I decided I was going to leave this January, January 2012. I was going to do it the right way. Start my own company. I already had the idea, the vision, you know, just getting it ready. And then this thing was thrown into my lap. Yeah, I was not happy with the company at all.
You were not happy because they were not making the kinds of choices that you had hoped?
Well, I know that in a big company they don’t have my best interests at heart. Only I can do that.
Right, but nor were they coming up with an attractive alternative. I mean, they weren’t making money.
… You have people in Occupy Wall Street that see this come down, and for them it’s just more evidence that greed never sleeps, regulators are always asleep, and that the rating agencies are behind the curve.
Yeah, it’s hard to disagree with, but I guess I’m a bit of an optimist. I feel like out of this calamity will be a better scenario, whether it’s going to be some type of insurance for commodities accounts or just an opening of eyes of the industry to make the changes.
I fully believe that if this situation would have happened 20 years ago, when Pat Arbor was the head of the [Chicago] Board of Trade — it was a private institution — if an FCM like MF blew up and there was customer money missing, they would have said: “All you guys, get in your office. You’re all sitting there. We make the customers whole, we figure out what the loss is, and then we get back to doing business.” Period.
But because it’s the CME’s, a publicly traded outfit, … they’re going, “Risk, risk.” It was them, but MF’s got their problems. And CFTC, I don’t know where they were through this whole mess.
You say you’re an optimist, but then you run down the scenario that —
I think there’s going to be some big changes. I really do. And maybe down the road I could be participating in that. I know there’s a lot of guys that are really trying to clean things up. And I can’t think of the gentleman’s name who’s running the customer coalition for MF —
You mean [James] Koutoulas?
Koutoulas. Great example. Here’s a guy that’s doing everything for all these customers, and I think a guy that could bring changes.
But he’s a lawyer that’s leading a lawsuit. I mean, he stands to make a lot of money.
Well, sure. That’s true. …
… When you see Occupy Wall Street demonstrations, what goes through your mind?
… Occupy Wall Street is very idealistic. It’s easy just to look at us and them, but we’re all connected.
Somebody was telling me a couple months ago, … “Wall Street made so much money in 2006, ’07 and ’08.” I’m like, “Well, we all did.” All the prices of our homes went sky high. Average income was going up. We all participated in the good years. I mean, we all do, you know, and it trickles out, and if we’re all making money, it just goes around.
Some people don’t like the downside of it too much, though?
Well, that’s true.
High unemployment, loss of retirement funds.
And then they see bankers getting large bonuses.
That’s one thing that’s interesting about this business, because when I signed up with Lind-Waldock, I made a percentage of overall commissions or fees generated, a percentage. Reasonable amount considered the total.
Reporters have turned that into bonuses, but the reality is, if you’re a player on Wall Street, you get a relatively small salary. You get the bonus as a percentage of your overall business. That’s called the bonus.
But people wouldn’t be doing these jobs without the bonus, so it’s actually kind of figured as your overall compensation for the year. So I know that a lot of us coming out of the MF thing didn’t get paid for 60 days.
So you think there’s a misperception of the inequity?
This question of whether or not MF Global was sufficiently recording its trades, you say that as far as you knew in your department, the controls were good?
The controls were great. We had compliance meetings all the time. We had an on-site legal staff that monitored all phone calls, all emails, all orders, any kind of business, solicitation, everything.
And compliance is complying with regulations, complying with doing things the way that they’re designed to be done?
This is regulation. This is where MF was at the time. We were way above the bar. No, because the concept was as a publicly traded company, you have to be squeaky clean. I mean, you’ve got to be, so to prevent anything that could be construed as not right, you go above and beyond, and that’s so you don’t have any problems.
MF Global gives Wall Street another black eye, right?
I believe so. Yeah.
Is it fair?
At this point, yes, absolutely.
Unfortunately for everybody involved. You bet. …