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 |
|---|---|---|---|---|---|
| SEC v. BlackRock Advisors, LLC (benchmark submission rigging, 2023) | SEC | 2023-10-24 | Benchmark Submission Rigging | $2.5m | settled |
| FCA v. Philippe Moryoussef Individual (benchmark submission rigging, 2022) | FCA | 2022-07-15 | Benchmark Submission Rigging | — | filed |
| FCA v. Colin Bermingham Individual (benchmark submission rigging, 2021) | FCA | 2021-09-27 | Benchmark Submission Rigging , Insider Trading | — | filed |
| OSC v. The Toronto-Dominion Bank (benchmark submission rigging, 2019) | OSC | 2019-08-26 | Benchmark Submission Rigging , Front Running +3 | — | settled |
| FCA v. Terry John Farr (benchmark submission rigging, 2019) | FCA | 2019-05-29 | Benchmark Submission Rigging , Wash Trading | — | judgment |