Submission-based benchmark
A submission-based benchmark is calculated from figures that panel members report rather than from observed transactions. The design invites manipulation, which is why post-scandal reform has pushed benchmarks toward transaction data.
Where does submission-based benchmark come up?
This term is used in the following manipulation techniques, each explained in full on its own page.
Enforcement actions involving these techniques
| Action | Agency | Filed | Technique | Penalty | Status |
|---|---|---|---|---|---|
| FCA v. Philippe Moryoussef Individual (benchmark submission rigging, 2022) | FCA | 2022-07-15 | Benchmark Submission Rigging | — | judgment |
| FCA v. Colin Bermingham Individual (benchmark submission rigging, 2021) | FCA | 2021-09-27 | Benchmark Submission Rigging | — | settled |
| FCA v. Terry John Farr (benchmark submission rigging, 2019) | FCA | 2019-05-29 | Benchmark Submission Rigging , Wash Trading | — | judgment |
| FCA v. Jonathan Mathew Individual (benchmark submission rigging, 2018) | FCA | 2018-10-30 | Benchmark Submission Rigging | — | judgment |
| CFTC v. Bank of America (benchmark submission rigging, 2018) | CFTC | 2018-09-19 | Benchmark Submission Rigging , Price Manipulation | $30m | judgment |