Futures Shock
Waldman, Steven
FUTURES SHOCK by Steven Waldman Stock futures take risks off investors and place them on the whole market R ecent press reports have blamed the volatility in the stock market on...
...These differences add up for the large institutional investors...
...If the investor had bought 1,000 contracts of the Standard & Poors stock index futures, he would have had to put up a margin of $10 million and would have incurred $80,000 in direct and indirect transaction costs...
...Although its funding has increased 50 percent since 1982, its staff is up only 15 percent...
...The 116-point January 23 drop seemed to be set off in part by investors using "technical analysis," the practice of charting broad market trends and selling off when the market seems to have reached a certain plateau, and in part by traders selling stocks and futures to exploit discrepancies between the stock and futures prices...
...At the same time, the officials warn, the possibility that they might also contribute to a meltdown is worth taking seriously...
...I'm not satisfied they know much about the stock market...
...This caused dramatic price drops in the stock market and several other agricultural commodities...
...Game of chicken So what is the problem...
...Perhaps if federal regulators put their minds to it, they could devise a less draconian but equally effective solution...
...It allows investors to play the stock market, but by a different set of rules—the rules of futures...
...Positive karma Futures supporters at the CFTC, the Chicago exchanges, and on Wall Street, argue that just because the futures movement preceded the stock plunge doesn't mean it caused it but merely that the futures pit was able to react faster to the bad news...
...Ideology aside, the CFTC's track record does not inspire confidence that this crucial area is in good hands...
...That's not quite as threatening as it sounds...
...Moreover, according to some studies, if you measure all the ups and downs of the markets in percentage terms, volatility has not increased...
...If the stock market declines, the investor's losses will be partially offset by the "gains" on the futures side...
...In addition, in 1984, executives of the Chicago Board of Trade Clearing Corp., an accounting arm of the Board of Trade, pleaded guilty to having illegally instructed more than 20 employees to make out personal checks to five congressmen...
...While the Federal Reserve System sets margins for the stock market, the exchanges set the margins for futures...
...this time it got there in seven minutes," he notes...
...Ironically, the strategy of hedging used to justify the stock index futures seems to help accelerate the market drops they are supposed to protect against...
...The CFTC had a tough time reconstructing the pattern of transactions because traders were required to record their activity only in half-hour intervals...
...If, for example, it is March 5 and a speculator believes the market will rise, he might buy one Standard & Poors futures contract worth roughly $140,000 by placing a margin deposit of $10,000...
...Since the firms investing in stock market futures are also involved in the questionable debtfinancing arrangements mentioned by Galbraith, it is not unreasonable to expect that some of their stable assets are paper thin...
...John Dingell, chairman of the Energy and Commerce Committee, had expressed interest in having the SEC take over stock indexes...
...Traders bristle at the suggestion, arguing that the market behaves wildly because of "market fundamentals," not because some financial tool is forcing it to...
...As the index goes down, traders clued in to the dropping market start selling stocks...
...But so far they have refused even to acknowledge there is a problem...
...If money managers investing for a pension fund fear their stock portfolio might lose value, they can sell index futures, in essence betting in New York that the securities will increase in value and in Chicago that they will shrink...
...Founded in 1974 in response to a wave of commodity futures frauds, the CFTC remains a small agency...
...It's almost as if an enterprise zone has been created within the stock market...
...The downturns in the markets have been merely a few sour notes in a chorus of hallelujahs...
...The futures trading helped fuel the market downturn...
...Jurisdiction over these financial tools fell to the CFTC as a result of a political agreement negotiated in 1982...
...During the Carter administration, the Commodities Futures Trading Commission (CFTC), the agency that regulates futures, blocked approval of stock index futures for fear they would cause stock market volatility and divert capital from securities...
...I do work for a lot of large portfolio managers, and for the first time they don't have to sell off stock every time they're scared," says Philip Johnson, formerly CFTC chairman and now a partner at the law firm Skadden Arps...
...In these and other cases, press accounts have pointed accusingly at the use of "computerized program trading," a term reminiscent of science fiction movies about feuding computers that start nuclear wars...
...The industry has been extremely active politically," notes former CFTC chairman, James Stone...
...To buy the equivalent 3.2 million shares of stock, the investor would have had to post about $140 million and would bear about $720,000 in transaction costs...
...In essence, you can play the stock market but, using futures rather than securities, can do it faster, easier, and cheaper...
...Another option would be to simply impose limits on how dramatically the futures market can shift in a day, a proposal that is considered virtually un-American by the industry but which is already in effect in most other futures markets...
...For example, in a January 1987 Atlantic Monthly article, John Kenneth Galbraith argued that there are several disquieting parallels between the two eras...
...Despite being frequently compared to legalized gambling, futures trading does serve some important economic functions...
...Some people say that the market would have reached that in the old days in three weeks...
...In the stock market, if an investor wants to sell 10,000 shares of General Motors, his broker doesn't just shout it out on the floor of the stock exchange and hope for the best...
...The regulatory goal in the stock market, he notes, has been preservation of a "fair and orderly" market, while the futures industry's "open and competitive" standard places no premium on order...
...The leverage on stock index futures should be unsettling given that the infamously low 10 percent margins on stocks in 1929 were higher than the current 7 percent margins on futures...
...Indeed, most of the recent growth in use of stack index futures has come from such investors...
...Buying and selling futures contracts also entails much lower "market impact costs' L–an investor is more likely to get a better price when making one transaction than when making several...
...in the U.S., it grew out of the desire of midwestern farmers to have a way of selling their produce with some certainty of the price...
...The scenario for a catastrophic meltdown is theoretical but commonsensical: The market starts heading down, perhaps because of some bad economic news—say, Paul Volcker oversleeps, causing worldwide financial panic...
...He focused on junk bonds and leveraged buy-outs, and the precarious tower of debt their use has created...
...Stock index futures just make it easier for the market to do what it wants to...
...brokerage firm and a network of banks that had lent them more than $1 billion...
...Selling," in this case, is the equivalent of placing a bet that the market is going to go down, the wager being in the form of a standardized contractual agreement...
...THE CHICKENS GUARDING THE CHICKEN COOP New Deal legislation eliminated many of the trading practices that caused the 1929 stock market collapse and, perhaps most important, created the Securities and Exchange Commission (SEC) to permanently stand watch and prevent a future crash from occurring...
...Now I think it could happen ." The next day he said he was thinking along the lines of a 600-point drop, adding, "A Boesky can undermine the credibility of the market...
...But such efforts may be inherently doomed because their most economically useful function—hedging under portfolio insurance plans--also helps accelerate plunges...
...Asked whether he was concerned that the stock index futures threatened the stock market, Lewis Horowitz, president of the New York Futures Exchange, declared, "Where there's risk, there's opportunity...
...In the last election, three PACs set up by commodity exchanges gave more than $500,000 in contributions...
...Johnson brokered an agreement with SEC chairman, John Shad, that split up the jurisdictions so the CFTC retained control over index futures while the SEC regulated a related product, options on the indexes...
...As the market starts to dip, computerized trading strategies kick in...
...The Dow Jones Industrial Average dropped 4.6 percent in September and 2 percent total on January 23...
...And why should they...
...in 1986 26.5 million contracts were, about three-fourths of it in the pits of the Chicago Mercantile Exchange...
...It recently went after the Phibro-Salomon investment firm for swindling its customers and proposed new requirements that might help ensure that exchanges can cover losses if there is significant futures movement...
...But mostly the din of Wall Street's partying has drowned out complaints that these might also lead to serious trouble...
...The difference is not hard to detect on the floor or in the futures prices...
...Such great indebtedness seems harmless enough when things are going well, but could be disastrous should a recession come and firms become less able to manage their debt...
...Their failure to do so threatened not only silver investors but other elements of the financial system, because the market collapse endangered the banks and brokerage houses that had lent the Hunts about $1 billion to cover their margin calls...
...Clayton Yeutter, the administration's trade representative and then president of the Chicago Mercantile Exchange, told The Wall Street Journal that the exchanges "took the initiative" in choosing all five members of the commission...
...Faced with dramatic and disorderly market conditions, the CFTC took none of the specific preventive or emergency actions allowed under the Commodity Exchange Act, although it had both the statutory duty to act and the requisite information," concluded a House subcommittee that investigated the event...
...Futures, for one thing, require much smaller margins...
...And anyway, stock index futures don't cause crashes, people do...
...Since the agreement, the CFTC has done nothing to temper the growth of stock index futures...
...If those stock values rise to $141,000 on March 6, the speculator that day could take his $1,000 profit...
...The more stocks that are sold, the more people sense a charging bear, and the lower the index goes, all of which triggers more stock sales and a rapid downward spiral...
...FUTURES SHOCK by Steven Waldman Stock futures take risks off investors and place them on the whole market R ecent press reports have blamed the volatility in the stock market on stock index futures and options...
...Futures give investors a certain security and may have helped fuel the stock market's recent growth by making institutional investors feel more comfortable buying securities...
...When they couldn't meet their margin calls, they endangered the Bache Halsey Stuart Shields Inc...
...Indeed, the growth of stock index futures seems even more ominous when considered in the context of other similarities between now and 1929...
...Stone suggests raising the margins as a way of ensuring that sharp futures market movement won't wipe out investors...
...The CFTC does not believe in much government intervention in the futures markets...
...More important, trading on the futures side is cheaper...
...Byrne suggests creating a stable futures trading system...
...As the Hunt brothers and their partners were buying up the world's silver supply, neither the CFTC nor the exchanges took strong action...
...The only logical plan, then, may be to abolish stock index futures...
...But its courage was short-lived...
...Take the case of a grain elevator operator who fears that the price of his corn will drop before it can be sold, perhaps because of a larger than expected corn crop...
...Although this volume is a small fraction of the stock market, it is being seen increasingly as the tail capable of wagging the dog...
...Nevertheless, the low margin levels are troubling...
...The growth in the market has been tempered by periodic plunges, the largest being the 86-point drop on September 11 and the 45-point drop on January 23, the day that saw the Dow Jones Industrial Average plummet 116 points in just over an hour...
...Traders start selling off stocks, not because of the gloomy economic news but because the futures contracts have dropped below the value of the equivalent bundle of actual stocks and they want to lock in a quick profit...
...But self-regulation also means that some rather important areas are left to the industry...
...Combine this with computerized trading strategies that enable—even encourage— investors to shift enormous amounts of money in seconds, and you have the potential for a dramatic change in the psychology of the market...
...They could agree to stand ready to take the opposite side of certain trades in exchange for special trading privileges...
...While the SEC has issued tough new rules to ferret out insidertrading cases, the CFTC has left that problem to the other government agencies that might be involved in the case...
...How can you sell something you don't have...
...Another example of the CFTC attitude toward regulation is insider trading...
...He tells a stock exchange "specialist," whose job is to find a buyer for those shares...
...The same debate has raged over agricultural commodities for years...
...Under these programs, investment managers will sell fixed portions of stocks or futures when the market drops by a certain amount, often 3 percent...
...For example, says Raesler, if an Agriculture Department employee leaks word of a wheat crop forecast to a Commodities trader, it is up to the Agriculture Department to find that employee and punish him or her...
...In 1984, the CFTC concluded that it didn't think dual trading was a big problem, but that it was difficult to know...
...He sells a futures contract in corn and locks in the price he will be paid, "hedging" against unpredictable market shifts...
...Or it may be a speculator whose interest is making money by betting the price of corn is going to go higher than the futures price...
...A 600-point drop wouldn't necessarily lead to a great depression, but in percentage terms it would be more than twice the size of the drop on October 28, 1929...
...Futures and options may not force the market down when it wants to go up, but they do seem to make it more likely that the trips downward will be dangerous...
...Sleeping better The frenzy of people screaming hysterically at each other in the futures trading pit has its origins in Renaissance Europe, at trade fairs where merchants and customers would meet and agree on purchases of products coming through town later...
...S.W...
...While in 1929 the other 90 percent of the stock cost was covered by debt—people getting in over their heads—the other 93 percent of the cost of futures is, or is supposed to be, covered by the actual assets of the investors...
...Regulatory agencies failed to intervene as the Hunts borrowed to make their payments, much as speculators had in the twenties...
...Robert Birnbaum, president of the New York Stock Exchange, warns that an initial slump, whether inspired by arbitrage or a case of the economic blues, may trigger another investment strategy known as computerized portfolio insurance...
...We just don't have the people to watch every trade and do all the enforcement ourselves ." In some areas, such as policing fringe operations and registering traders, the National Futures Association, a self-regulatory body set up by the industry in 1982, has been effective and has relieved the CFTC of a substantial burden...
...In fact, probably the scariest thing about the recent plunges is that they've all taken place at a time when positive economic karma pervaded...
...So, one exaggerated fall could trigger another exaggerated fall, all within a matter of minutes...
...There may be a solution that would preserve the benefits of stock index futures while minimizing their potential dangers...
...The value of the Standard & Poors stock index futures contract, for example, rises and falls according to the price movement of 500 different stocks...
...farmers often claim that futures speculation drives down the price of the crop, while futures traders claim crop performance drives the price of the futures...
...The only difference between pork belly Steven Waldman is an editor of The Washington Monthly...
...In return, he or she gets special trading privileges...
...In one important respect the silver crisis presents different problems than stock index futures...
...They can sleep better at night" But at the same time, these leaders warn of the danger of futures trading...
...What would index futures and computerized trading do to the market if people became convinced that bad times were ahead...
...Industry representatives have long exerted great influence over the commission, either directly or through members of Congress...
...Although program trading has become a catchall phrase, it usually refers to "arbitrage," which sounds daring but is actually a strategy that institutional investors can use to lock in risk-free profits by exploiting differences that develop between the value of the actual stocks and the futures contract...
...Industry self-regulation does work extremely well," says Kenneth Raesler, the CFTC general counsel...
...The classic case of both industry selfregulatory and CFTC regulatory failure was the silver crash of 1980...
...the more it does, the more it will make minor downturns into major ones...
...Should such a rapid shift happen at the same time other blocks are crumbling beneath the nation's house of debt, the stock index futures could help transform a serious problem into a catastrophe...
...When it held hearings last year on legislation to reauthorize the CFTC for three years, the topic of the potential effects of stock index futures barely came up, even though the market had experienced several deep drops that had been partially attributed to program trading and futures...
...That's unfortunate because some of those warning of trouble are in a position to know...
...If, however, the market heads down sharply, the speculator would immediately feel the pinch...
...If you think the stock market is moving up you can react more quickly and easily on the futures side...
...The value of pension funds could drop, companies might have to lay off workers for lack of modernization capital, banks might be destabilized because their investment portfolios or too many of their customers were injured in the stock market, and, in general, pessimism would guide economic decisions...
...It adds fuel to the fire to see those red sell tickets pouring down onto the floor...
...In the late seventies, trade began on financial futures, including contracts for products such as deutsche marks, Treasury bills, bonds and government-backed mortgages...
...The combination of stock index futures and computerized program trading has created a suped-up stock market...
...The hedger in this case—the equivalent of the grain elevator operator—is the large-scale stock market investor...
...Confronted with this news, traders start selling off stock index futures, betting that the stock market will go down...
...But the triple-witchinghour phenomenon may be overblown...
...In weighing the pros and cons of the futures, the industry simply emphasizes a different set of concerns than government should...
...That is precisely what happened in the January 23 drop...
...For its size it's as politically active as any industry in the country...
...Although most of the debate has focused on futures because they are more widely used, options function much the same way, the main difference being that a futures contract confers an obligation to buy or sell, while an option merely gives the right to...
...Even the CFTC's harshest critics have said the agency has been making progress, becoming more aggressive with each year...
...In 1982, the General Accounting Office (GAO) concluded that the CFTC's surveillance had remained small as trading had mushroomed and that it had relied too much on industry self-regulation "rather than on the substance of rule enforcement ." The GAO proposed a user fee, similar to the one securities brokers pay to help finance the SEC, to help pay for stricter CFTC enforcement...
...A sour chorus One way to minimize the danger of stock index futures is to make them more like securities...
...As noted earlier, the existence of stock index futures creates a market dynamic that increases the chances that such a scenario would develop...
...Although some exchanges have implemented time stamping, others are adopting a system that would not provide regulators as much information as strict accounting of transaction times...
...During that time the volume of futures trading has doubled...
...These market innovations have yet to be recession-tested...
...A 1985 Common Cause study showed that in earlier elections, individual commodity traders had given more than $200,000 and that the exchanges regularly give more than $100,000 in honoraria to members...
...The most egregious example of CFTC weakness is its failure to do anything about stock index futures...
...If the specialist can't find a buyer he is obligated to buy himself...
...In the case of a stock index future, speculators bet that a group of stocks is going to go up or down in value...
...During the recent drops in the market as well as many of the surges, traders reported that stock market movement was preceded by feverish trading in the futures pits...
...Perhaps the market would drop just as drastically without stock index futures, but it seems that during the recent plunges trading was reacting not to economic news, but to market news, which was being shaped by the index futures and computerized trading...
...If such an arrangement existed, a flood of futures sell orders could be immediately counter-balanced by some large buy orders, thereby keeping the price from dropping too quickly...
...Johnson had support from the agriculture committees in Congress, which were not pleased with the prospect of giving up their jurisdiction over such an important area, particularly given the political influence of the Chicago exchanges in pushing the futures...
...When the stock market is suddenly hit with an avalanche of sell orders, everyone goes 'Oh my God,' " says Jeffrey Miller, of the investment firm of Miller and Tabak, who helped pioneer the use of these futures but now has doubts...
...The committee has so far shown little interest in stock index futures...
...The standard definition of a future is simple: a contract to purchase a commodity, such as corn or hogs, at a given price and time in the future...
...These guaranteed buyers keep the price of stocks from dropping like that of bald tires at a garage sale...
...When the Hunt brothers tried to corner the silver market in 1980, what should have been a silver crisis almost turned into a larger financial disaster...
...After the industry had blasted the CFTC's proposal as meddlesome and disruptive, CFTC chairwoman, Susan Phillips, quickly told Congress she would be satisfied with 70 or 80 percent compliance during busy periods and clarified that the rules were merely standards that the exchanges could meet any number of ways...
...In addition, the CFTC has few people at the exchanges to monitor either market swings or irregular trading...
...But Birnbaum is skeptical...
...Portfolio insurance covers about $50 billion of roughly $1 trillion in pension fund assets, and that portion is growing steadily...
...That is why leaders of the New York Stock Exchange hail the benefits of stock index futures...
...It is much harder to pile paper debts on top of each other in the futures markets since big losers must pay up at the end of each day...
...Neither institutional investors nor speculators invest entirely on the basis of the cash they have on hand...
...The speculator could have sold futures also...
...Although arbitrage does lead to sudden bursts of trading in the closing hour of those quarterly expiration days, most of the largest swings have not taken place then...
...Arbitrage has been blamed for market swings on "triple-witching-hour" days when the stock index futures and other equityrelated options all expire...
...It would mean that on average the price value of stocks would decrease by close to 30 percent...
...And futures can have the effect of throwing oil on a fire...
...On December 11, as the stock market entered the final turn in its wind sprint toward 2,000, John Phelan, chairman of the New York Stock Exchange, suggested that stock index futures, in combination with certain recent trading strategies, might cause the market to experience a "meltdown" "lino years ago, I would have said no," Phelan told a meeting of Gannett Newspaper editors...
...With stock index futures, which were first traded in 1982, the "commodity" is a bundle of stocks...
...But when Senator William Roth proposed a fee of 6 to 12 cents per transaction, a tiny fraction of what traders pay in brokerage fees, the industry rebelled and beat back the proposal...
...The whole thing just keeps cascading down," Birnbaum says...
...Five years ago, five million of the contracts were traded...
...Occasionally, warnings are heard in the news about stock index futures and their relationship to computerized "program trading," usually when the stock market's euphoria is interrupted by a brief plunge, like the 116-point dive it took in 71 minutes on January 23...
...In large part, this is because they represent the Reagan administration's anti-regulatory sentiment...
...He would have to add money to his initial margin deposit in order to hold onto his contract...
...Research assistance by Caitlin James...
...Most of its staff of 500 fits on five floors of a downtown Washington office building with a "space available" sign in the lobby...
...The CFTC proposed mandatory one-minute time stamping so it could determine the sequence of trades...
...I have no doubt that the credit extension and internal leverage of firms are at all-time highs," says James Stone, the chairman of the CFTC under President Carter...
...If a trader knows he's about to execute a large purchase that will send the price of the commodity up, he may first buy some futures for himself...
...They are instead regulated by the 13-year-old Commodity Futures Trading Commission (CFTC), an agency set up primarily to regulate agricultural and mineral trade...
...To give security to particular investors, the futures endanger the entire market...
...futures and stock index futures, then, is that in the first case if something goes very wrong, the nation could suffer a bacon shortage, in the second, a financial collapse...
...Stock index futures, however, are not stocks and are therefore not regulated by the SEC...
...While the SEC has 40 percent of its SEC staff in regional offices, the CFTC keeps only about 25 percent of its staff in the field...
...Despite its much publicized aggressive pursuit of insider traders, even the SEC has so far agreed with the CFTC actions—and inaction— on financial futures...
...The CFTC and the exchanges could also be more aggressive in encouraging large investment firms to undertake a similar function in the stock index futures arena...
...It is, to put it in terms of broiler futures, the ancient financial question: Which came first, the chicken or the chicken future...
...This prospect caused shivers in the futures industry, which viewed the SEC as a more intrusive regulator, particularly when spurred on by Dingell, who had proposed a moratorium on stock index futures...
...Even well-heeled investors who bet the wrong way on a dramatically shifting futures market might have trouble meeting their margin calls...
...Its budget is one-fourth that of the SEC...
...Portfolio insurance programs were a major factor in the September downturn...
...Dan Glickman, a member of the House Agriculture Committee, charitably described it as "an inconsistent parent who one day overdisciplines a child and the next day looks the other way as the child destroys his neighbor's house...
...Defenders of the system insist that regardless of the scenario, futures are simply a lubricant, enabling the market to get where it was going faster than in the pre-computer age, and making the market more efficient...
...In response to the silver crisis, the CFTC did strengthen limits on the amount of contracts one investor can hold...
...He noted in particular a trend toward excessive speculation and fondness for that magical financial concept, "leverage," in which small amounts of money create the potential for large profits—and large losses...
...This type of trading . ..can destroy the market ." Some New York Stock Exchange officials agree with futures advocates that these new instruments help the stock market in many ways and may even be partly responsible for its rapid growth...
...The brokerage fees for institutions buying one contract is about $30, compared to about $300 (or several times that amount at retail prices) for the several transactions needed to purchase an equivalent amount of stock...
...In 1982 the Reagan administration CFTC approved the trade of these futures as well as options...
...Tom Byrne, who works at the index and options desk of Shearson Lehman and is the author of The Stock Index Futures Market, thinks the main problem with futures proliferation is the creation of a "commodities mindset" in the securities industry...
...In part the budget has stayed small because of fiscal austerity, in part because the industry has wanted it to...
...When the Reagan administration was seeking new commissioners for the CFTC in 1982, they relied heavily on friends at the exchanges for the names...
...While stocks require deposits of at least 50 percent, futures deposits are roughly 7 percent (recently raised from 4 percent...
...During the previous two years, the Hunt brothers, in an attempt to corner the silver market, feverishly bought silver futures and sent the metal's price from $10 to $50 an ounce and then back down to $10 in three months, including a one-day drop of 32 percent...
...The purchaser might be a processor like General Foods, which fears that prices are going to rise and wants to preserve a low price...
...For larger quantities of stock, the major brokerage firms seek out the opposite sides of trades before they go to the floor...
...You just don't give something up in Congress," says Glickman...
...It's like the National Rifle Association says about guns," explains market analyst Jeffrey Miller, referring to the lobby's motto that guns don't kill, people do...
...Not surprisingly, though, the biggest beneficiaries of industry generosity are the Agriculture Committee members, who now receive about one-third of the PACs' contributions...
...even the Ewings and Carringtons in collusion couldn't corner the stock market...
...The answer is that the effects on market confidence would be starkly different...
...The CFTC has even taken a step toward clamping down on "dual trading," in which floor brokers make deals for themselves before their customers...
...Futures traders thrive on volatility, big shifts, and great leverage, all values that do not lend stability to the stock market...
...After such a drop, roughly equivalent in percentage terms to Black Tuesday in 1929, large investors would be more likely to say, "Let's take our $5 billion of fiduciary responsibility out of here," than, "Don't worry, we'll just wait for the market correction ." At any rate, given our debt-burdened economy, it is not entirely reassuring to think that the market is going to plunge uncontrollably only if there's bad economic news...
...The case did, however, point up the dangers of lax regulation...
...I'm satisfied they [the CFTC] know a lot about sow bellies," Dingell said in one hearing...
...You've got to look at the market and say, Is everyone willing to invest in the market and accept a 300-point downturn in one day rather than over a period of months...
...Unfortunately, his analogy is perfect...
...This is one area where self-regulation is not sufficient...
...Hearing Dingell's footsteps, the CFTC chairman, Philip Johnson, moved to preempt him...
Vol. 19 • March 1987 • No. 2
