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Posts Tagged ‘white collar crime’

Citigroup Saw Warning Signs, Knew Of Madoff Fraud; Picard Suit Wants $430M In Damages

Courtesy of The Daily Bail

Source – Bloomberg

Citigroup ignored warning signs of Bernard L. Madoff’s Ponzi scheme, and a bank executive knew the con man’s stated trading strategy couldn’t generate the reported returns, the trustee liquidating Madoff’s firm said in a lawsuit.

The unidentified Citibank executive, who was responsible for making recommendations to clients on derivatives, “concluded” by June 2007 that returns reported by a Madoff feeder fund, Fairfield Sentry Ltd., couldn’t have come from the strategy, trustee Irving Picard said in a complaint unsealed yesterday. The executive reached his conclusion after meeting with analyst Harry Markopolos, a whistleblower who also alerted U.S. regulators to the fraud, Picard said.

The Citibank official later communicated with Markopolos orally and in writing, specifically discussing the fraud before the Ponzi scheme was exposed in December 2008, Picard alleged.

“Citi knew, and was on notice of, irregularities and problems concerning the trades reported by BLMIS, and strategically chose to ignore these concerns in order to continue to enrich themselves,” Picard said in the complaint, referring to Madoff’s firm, Bernard L. Madoff Investment Securities LLC.

Picard laid out in the complaint details of a lawsuit he filed under seal in December against New York-based Citigroup and other banks. He is demanding $425 million from Citigroup – money it received “in connection with” a loan to a Madoff feeder fund and a swap transaction with a Swiss hedge fund linked to a second feeder fund, Picard said.

Continue reading at Bloomberg…

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We first got an inkling of Picard’s filing from this Bloomberg story in December.

Citigroup, Bank of America Sued by Madoff Trustee

Citigroup Inc.’s Citibank, Bank of America Corp.’s Merrill Lynch unit and five other banks were sued by the trustee liquidating Bernard Madoff’s firm to recover more than $1 billion for the con man’s defrauded customers.

The banks, which include Natixis SA, Fortis Prime Fund Solutions Bank (Ireland) Ltd., ABN Amro Bank NV, Nomura Bank International Plc. and Banco Bilbao Vizcaya Argentaria SA, received money through Madoff feeder funds when they knew, or should have known, that Madoff’s investments were a fraud, the trustee, Irving Picard, said yesterday in a statement.

Picard, who faces a two-year legal deadline that runs out Dec. 11, has filed hundreds of suits in the past month, seeking more than $34 billion from banks, feeder funds, investors and others alleged to have profited from Madoff’s decades-long Ponzi scheme, the biggest in…
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Insider Trading Is Legal For Members Of Congress – And They Refuse To Pass A Law That Would Change That

Insider Trading Is Legal For Members Of Congress – And They Refuse To Pass A Law That Would Change That

Courtesy of Michael Snyder at The American Dream

Is insider trading wrong?  Most Americans would say that it is.  In fact, some very wealthy and very prominent Americans (including Martha Stewart) have gone to prison for it.  It just is not right for those with inside information that is not generally available to the public to make huge profits in the stock market by making key trades based on that information. 

But there is one group, members of the U.S. Congress, that can do all the insider trading they want and get away with it.  That is because insider trading is perfectly legal for members of Congress.  Yes, you read that correctly.  So how would that work?  Well, for example, a member of Congress may know that a law that is about to be proposed would have a very positive effect on a particular company and could buy up a ton of stock in that company a few days before that law is introduced.  Isn’t that wrong?  Of course.  Is there any law against it?  Not at all. 

You would think that some of the more ethical members of Congress would want to close this glaring loophole, but it just isn’t happening.  Legislation has been introduced from time to time that would end this practice, but it has gotten very, very little support.  The Wall Street Journal recently published an article about this issue which described the current situation this way….

"A few lawmakers proposed a bill that would prevent members and employees of Congress from trading securities based on nonpublic information they obtain. The legislation has languished since 2006."

But even though insider trading is legal for members of…
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The Art of Spinning: How to Identify Possible White Collar Criminals or at Least Unethical and Deceitful People Who You Should Avoid

Sam wrote this timeless piece a few years ago but searched it out specially for us. For non-criminal types, this article is pretty depressing, but if you feel entangled in one of these criminal-non-criminal, or unethical-ethical person, relationships, it behooves you to know how the game is played. If you are an aspiring white collar criminal, this essay can be used as a how-to manual. – Ilene 

The Art of Spinning: How to Identify Possible White Collar Criminals or at Least Unethical and Deceitful People Who You Should Avoid

sam antar Courtesy of Sam Antar 

White collar crime is a crime of persuasion and deceit. Since the white collar criminal uses persuasion and deceit to commit their crimes, it follows that such felons are artful liars.

People often ask me what characteristics I look for in other people that alert me to possible criminal activity or at least unethical and deceitful people.

Not all questionable conduct is illegal. A person can be unethical or deceitful (however they are defined) without committing any illegal acts as defined under the law.

However, most criminals use tools like spinning (see below) in the conduct of their crimes.

The Art of Spinning:

  • Sell people hope. My cousin ‘Crazy Eddie’ Antar taught me that “people live on hope” and their hopes and dreams must be fed through our spin and lies. In any situation, if possible, accentuate the positive.
  • Make excuses as long as you can. Try to have your excuses based on at least one truthful fact even if the fact is unrelated to your actions and argument.
  • When you cannot dispute the underlying facts, accept them as true but rationalize your actions. You are allowed to make mistakes as long as you have no wrongful intent. Being stupid is not a crime.
  • Always say in words you “take responsibility” but try to indirectly shift the blame on other people and factors. You need to portray yourself as a “stand up” guy or gal.
  • When you cannot defend your actions or arguments attack the messenger to detract attention from your questionable actions.
  • Always show your kindness by doing people favors. You will require the gratitude of such people to come to your aid and defend you.
  • Build up your stature, integrity, and credibility by publicizing the good deeds you have done in areas unrelated to the subject of scrutiny.
  • Build a


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My Life as a White-Collar Criminal

My Life as a White-Collar Criminal

Courtesy of Sam Antar at White Collar Fraud 

Last Friday evening, Marcia MacMillan from CTV News Channel (a 24-hour news network in Canada) interviewed me and asked me what it’s like to be a white-collar criminal and what role, if any, did morality play in my decisions to commit crime. 

 

You can watch the interview by clicking on this link.

Reflecting on my own white-collar criminal mind leaves no doubt that money is not the only motivating force compelling hardcore criminals to commit crimes.  There was also a passion for the act, a sense of accomplishment, that made me enjoy committing my crimes. It is perhaps the same positive feelings of success that law-abiding citizens experience for a legitimate job well-done.  

To better understand the behavior of white-collar criminals, take morality out of the equation. During my years at Crazy Eddie, we never had a single conversation about the morality of our actions. We did not give a damn about right and wrong.

Hardcore criminals don’t question their unethical and immoral conduct.  Laws, morality, and ethics are weaknesses of other people. They don’t factor in except by limiting society’s behavior. In our society, morality dictates that people are entitled to the benefit of the doubt. Ironically, the “benefit of a doubt” limits the behavior of law-abiding citizens while giving criminals greater opportunity to commit their crimes.  After all, no one likes to be called "a paranoid" or "impolite."  

Our late President Ronald Reagan used to say "trust, but verify." That initial trust gives criminals the freedom to take steps to evade detection.  For example, Joseph T. Wells, founder of the Association of Certified Fraud Examiners, described certain steps I took during Crazy Eddie’s audit to successfully execute my crimes: 

Crazy Eddie’s auditors were provided a company office during their examination. They had a key to lock the desk—which they kept in a box of paperclips on top of the desk in full view. After the auditors left for the day, Eddie’s cohorts would unlock the desk, increase the inventory counts on the work-papers and photocopy the altered records. Were the auditors stupid? No, just too trusting. After all, no one wants…
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How White-Collar Criminals Exploit Your Vanity – Beware of Compliments

Career criminal, master charmer Sam E. writes about his speaking engagement in Portland, where we met and I gathered material for part II of the No Redemption. The most fascinating aspect of Sam’s story is what his admissions teach us about human nature. But on a more practical level, understanding fraud and the techniques used to commit white collar crimes can give investors insight into the integrity of the companies they invest in. Companies built on fraud tend to implode under the weight of their own lies, eventually – can we find these companies early, before their business comes crashing down?  (Stay tuned for part III) – Ilene 

How White-Collar Criminals Exploit Your Vanity – Beware of Compliments

By Sam Antar of White Collar Fraud 

Artwork by Marta Dahlig

Last Friday, I was the key note speaker at the Oregon Health Care Fraud Working Group Training Seminar, sponsored by the United State Attorney’s Office for the District of Oregon. I explained to the group that while emphasis on effective oversight and internal controls are important factors in preventing or deterring white-collar crime, not enough emphasis is given to the underlying psychology used by white-collar criminals to prey on their victims and effectively commit their crimes.

I have said many times that, "White-collar criminals consider your humanity as a weakness to be exploited in the execution of their crimes" and as the cold-blooded and ruthless criminal CFO of Crazy Eddie, I learned that you can steal far more with a smile than you can with a gun.

White-collar criminals use a combination of charm and deceit to achieve their objectives. The more likable and charming that I was as a criminal, the easier it was for me to successfully lie to my victims…
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No Redemption II

No Redemption II

By Ilene 

(This is part two of my interview with Sam E. Antar. For more, read No Redemption I.)

Sam Antar, former CFO of the criminal enterprise “Crazy Eddie,” gave a lively and educational lecture on white collar crime in Portland to health care fraud investigators yesterday on behalf of the United States Department of Justice. He spoke about Crazy Eddie, white collar criminals, and the investigators charged with bringing them to justice.  In the beginning of the seminar, Sam asked the audience, “Can anyone guess why I’m here?”  A man raised his hand and suggested “because you got caught.” That was apparently the first correct answer to that question in twelve years. 

Sam E. Antar

Here is what else Sam told heath care fraud investigators:

About fraud

“All fraud is basically the same.  All fraud is personal in nature. It’s done on a one to one basis.  Your humanity, ethics, and sense of fairness are weaknesses that we – white collar criminals – seek to exploit.  We have no morality. The more likable and friendly we are, the easier it is for us to commit our crimes. We build walls of false integrity.  You never know who the real person is behind a criminal’s carefully choreographed wall of false integrity. Bernie Madoff had a wall of false integrity around him and the lawyers investigating him at the SEC were enamored by his status. That’s why they didn’t properly follow through on whistleblower Harry Markopolos’s tips about Madoff’s criminal activities. 

“Punishment does very little to prevent crime.  It’s not a great deterrent. Criminals don’t stop because they see other people getting caught. While Bernie Madoff committed his crimes for almost two decades, he saw many other criminal get caught. Did that stop him?

“When I cooperated with the government it was only to save my own skin. I only cooperated with the US Attorney’s Office, the FBI, the SEC, and lawyer representing victims of my crimes because I did not want to bend down to pick up a bar of soap and worry about who was going to be my boy friend.”

Fraud Triangle/Diamond

“Criminologists have identified three common elements to all white collar crime: incentive, opportunity, and rationalization. It’s known as the fraud triangle. In recent years, capability was added as a common element of white collar crime and the fraud triangle…
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No Redemption

No Redemption

"Homo sum, humani nihil a me alienum puto."  Terence

Interview with Sam Antar, by Ilene, part 1.

Crazy EddieSam Antar will tell you all about his crimes, in every last detail, while insisting he is and always will be a criminal, and will burn in Hell for the massive amounts of harm and destruction to lives he has caused. 

My initial reaction was not to believe Sam, being sure, having never spoken with him before, and not knowing much about Crazy Eddie, that Sam was mistaken about burning in Hell. After all, he is now teaching others all about white collar crime and the perpetrators of those crimes. Guilt is such a deadly emotion, and you don’t even have to be aware of it suffer its assaults on your psyche. He’s probably plagued with guilt, I surmised. Which would mean he’s not a sociopath. Of course, I am not a sociopath and have no insight into the sociopathic mind. But I felt eager to learn. Besides, Sam warned me not to believe a word he said.

Before our interview began, Sam shared the basic tactics that white collar criminals use to exploit and scam their victims:

1. White collar criminals consider your humanity, ethics, and good intentions as a weakness to be exploited in the execution of their crimes.
2. White collar criminals measure their effectiveness by the comfort level of their victims.
3. White collar criminals build a wall of false integrity around them to gain the trust of their victims.

At this point, I was feeling comfortable with Sam, admiring his self-insight and commitment to telling the truth.  So when Sam said that by the time he was finished with me, I’d be a paranoid schizophrenic and never trust another man again, I was again thinking he was wrong. Just like the ideal victim type I am. 

Ilene: Sam, you wrote on your website “I am a convicted felon and a former CPA. As the criminal CFO of Crazy Eddie, I helped Eddie Antar and other family members mastermind one of the largest securities frauds uncovered during the 1980s. My responsibilities at Crazy Eddie included skimming, money laundering, insurance fraud, securities fraud, and a list of other criminal activities too long to list here.”  Could you elaborate on what you were doing?

Sam Antar and Crazy EddieSam: Committing white collar…
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The Real Reason Behind Danny DeVito’s Crazy Eddie Movie Project Meltdown from Eddie Antar’s Cousin and Criminal CFO Sam E. Antar

The best way to learn about white collar crime is from a white collar criminal. Sam Antar teaches on the subject, and will warn you, DON’T TRUST ME. – Ilene 

Do not trust, just verify. Verify, verify, and verify. – Sam Antar

The Real Reason Behind Danny DeVito’s Crazy Eddie Movie Project Meltdown from Eddie Antar’s Cousin and Criminal CFO Sam E. Antar

Danny DeVitoCourtesy of Sam Antar at White Collar Fraud 

In an exclusive interview with Mike Fleming from Deadline New York, Producer and Director Danny DeVito whines about how problems in obtaining Eddie Antar’s life rights essentially sunk his Crazy Eddie movie project. However, Danny DeVito does not tell the whole story to Mike Fleming.

Apparently, Danny DeVito wanted to do a story that glamorized Eddie Antar and portray him as some sort of misguided hero. As the other "main character" in our frauds, I will have no part of any production that is sympathetic to any character, including myself, for our heinous cold-blooded crimes.

In addition, DeVito has made a series of troubling comments to the press about how he apparently tried to side step defrauded thousands of investors who are owed hundreds of millions of dollars in civil judgments, while clearly showing his sympathy to Eddie Antar.

We deserve to rot in hell for our unforgivable crimes

Over the last twenty years, I have said publicly that as the criminal CFO of Crazy Eddie my crimes were pure evil and I deserve to fry in hell for my unforgivable sins. I’ve made no excuses for my criminal conduct. At Crazy Eddie, we committed our crimes for both fun and profit. We arrogantly committed our crimes simply because we could and we had no empathy whatsoever for any of our victims. 

Continue here.>> 


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Control Frauds HyperInflate and Extend Bubbles Maximizing Damage – A Control Fraud at Work in the Silver Market Short Positions?

Control Frauds HyperInflate and Extend Bubbles Maximizing Damage – A Control Fraud at Work in the Silver Market Short Positions?

Courtesy of JESSE’S CAFÉ AMÉRICAIN

Here is a working paper by William K. Black about ‘control frauds’ and how they relate to the most recent credit crisis in the United States, a breakdown of stewardship that has placed the rest of the world’s financial sector at risk as well.

Control frauds are by their very nature conspiratorial in that they involve the suborning of regulators, ratings agencies, exchanges, the media, and legislators to ignore and facilitate misrepresentation that enable white collar crime. They are difficult to prosecute because by their nature they involve twisting the legal into the extra-legal on a broad basis to achieve a particular financial effect, while limiting many specific aspects to the letter of the law, or at least the gray areas.

By and large they operate in the shadows, hiding behind secrecy and a general mindset towards short term greed and lapses in ethics. Investigations following the Crash of 1929 and the S&L crisis demonstrated that the existence of such pervasive lapses in stewardship do exist.

Personally I think the significant short positions in the silver market may be a form of control fraud. This is why so much effort and care is being taken by some individuals and groups to discover the extent and nature and holders of the short positions that are dominant. And this is why the participants are so vociferous and secretive regarding their activities.

To those who say that the commodity markets are too large, and too well regulated for this sort of thing to occur, this is the sort of fraud that Enron used to manipulate the energy markets, to the extent that they were able to cause significant social and commercial disruption to the state of California.

More on this another time. For now understanding how these frauds work is enough to study in instruments such as home mortgages. And most people do not need to understand this. But here is a good point for the average person to keep in mind.

Light is a good disinfectant. Fraud cannot bear exposure. While some confidentiality must be maintained in trading, obsessive secrecy regarding significantly large positions and collateral matters is often an indication that something is not right, that it is hidden from the market participants view for…
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Goldman, Sears, Others Named In Insider Trading Subpoenas

Goldman, Sears, Others Named In Insider Trading Subpoenas (GS, SHLD)

Courtesy of Clusterstock, by Lawrence Delevingne

 

 


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Chart School

Disturbing Charts: New Update

Courtesy of Doug Short.

Advisor Perspectives welcomes guest contributions. The views presented here do not necessarily represent those of Advisor Perspectives.

I find the following charts to be disturbing. These charts would be disturbing at any point in the economic cycle; that they (on average) depict such a tenuous situation now ? 58 months after the official (as per the September 20, 2010 NBER BCDC announcement) June 2009 end of the recession ? is especially notable.

These charts raise a lot of questions. As well, they highlight the "atypical" nature of our economic situation from a long-term historical perspective.

All of these charts (except one, as noted) are from the Federal Reserve, and represent the most recently updated data.

The following eight charts are from the St. Louis...



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Zero Hedge

Housing Starts, Permits Miss As Rental Euphoria Fizzles

Courtesy of ZeroHedge. View original post here.

Submitted by Tyler Durden.

While both the Housing Starts and Permits data reported moments ago disappointed - and sorry, you can't blame it on weather this time - with both sets of data missing expectations (Starts 946K, Exp. 970K up from a revised 920K; Permits 990K, Exp. 1010K down from a revised 1014K), the real story was in the composition of single family vs multi-family, or rental units, which showed that the previously reported rental euphoria has well and truly fizzled after a dead cat bounce in last 2013 could not be sustained. And perhaps more importantly, the complete lack of any real bounce in single-family housing, which remains at levels seen in late 2012 for starts, and is now rolling over for permits, confirms that ...



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Phil's Favorites

Gold Doomed or Resting? Gold vs. Major Currencies; Goldman Sachs and Morgan Stanley Reiterate Sell Signal

Courtesy of Mish.

Here are some interesting charts from my friend Nick at Sharelynx Gold. (Login Required)

Gold vs. US Dollars



Gold vs. Euros



Gold vs. Ukraine Hyyvnia



It took about 4,000 Hyyvnia to buy an ounce of gold at the end of 2008. It takes 17,444 now....



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Insider Scoop

UPDATE: Zogenix-Says Court Granted Temporary Restraining Order Preventing Implementation of Massachusetts Ban of Zohydro ER Extended-Release Capsules =8-K

Courtesy of Benzinga.

On April 15, 2014, Zogenix (NASDAQ: ZGNX) announced that, in connection with the previously disclosed lawsuit that the Company filed in the U.S. District Court in Massachusetts requesting a temporary restraining order preventing the implementation of the Commonwealth's ban of Zohydro™ ER (hydrocodone bitartrate) extended-release capsules, the Court entered such order on Constitutional grounds. This order will become effective on April 22, 2014.

Posted-In: News Guidance Legal

...

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All About Trends

Mid-Day Update

Reminder: David is available to chat with Members, comments are found below each post.

Click here for the full report.




To learn more, sign up for David's free newsletter and receive the free report from All About Trends - "How To Outperform 90% Of Wall Street With Just $500 A Week." Tell David PSW sent you. - Ilene...

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Sabrient

What the Market Wants: Positive News and Stocks at Bargain Prices

Courtesy of David Brown, Sabrient Systems and Gradient Analytics

Last week’s market performance was nasty again, especially for the Small-cap Growth style/cap, down 4%.  Large-caps faired the best, losing only 2.7%.  That’s ugly and today’s market seemed likely to be uglier today with escalating tensions over the weekend in Ukraine. 

But once again, positive economic trumped the beating of the war drums. Retail Sales jumped up 1.1% over a projected 0.8% and last month’s tepid 0.3%, which was revised up to 0.7%.  While autos led, sales were up solidly overall.  Business inventories were about as expected with a positive tone.  Citigroup (C) handily beat estimates to add to the morning’s surprises.  As a result, the market was positive through most of the day, led by the DJI, up 0.91%, and the S&P 500, up 0.82%.  NASDAQ had a less...



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Digital Currencies

Facebook Takes Life Seriously and Moves To Create Its Own Virtual Currency, Increases UltraCoin Valuation Significantly

Courtesy of ZeroHedge. View original post here.

Submitted by Reggie Middleton.

The Financial Times reports:

[Facebook] The social network is only weeks away from obtaining regulatory approval in Ireland for a service that would allow its users to store money on Facebook and use it to pay and exchange money with others, according to several people involved in the process. 

The authorisation from Ireland’s central bank to become an “e-money” institution would allow ...



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OpTrader

Swing trading portfolio - week of April 14th 2014

Reminder: OpTrader is available to chat with Members, comments are found below each post.

This post is for all our live virtual trade ideas and daily comments. Please click on "comments" below to follow our live discussion. All of our current  trades are listed in the spreadsheet below, with entry price (1/2 in and All in), and exit prices (1/3 out, 2/3 out, and All out).

We also indicate our stop, which is most of the time the "5 day moving average". All trades, unless indicated, are front-month ATM options. 

Please feel free to participate in the discussion and ask any questions you might have about this virtual portfolio, by clicking on the "comments" link right below.

To learn more about the swing trading virtual portfolio (strategy, performance, FAQ, etc.), please click here...



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Market Shadows

Winning: Defined as Losing Less

By Paul Price of Market Shadows

Market Shadows Excelled – With a 1.36% Weekly Decline

In the land of the blind, the one-eyed man is King. Our Virtual Value Porfolio took on that role this week as we lost a modest 1.36% of our value while the DJIA, S&P 500 and Nasdaq Composite dropped from 2.35% - 3.10%.

We remain bullish despite the shaky end of week sentiment. Our original $100,000 now totals $145,058 including our 2.8% cash reserve.

 ...



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Stock World Weekly

Stock World Weekly

Newsletter writers are available to chat with Members regarding topics presented in SWW, comments are found below each post.

Here is the new Stock World Weekly. Please sign in with your user name and password, or sign up for a free trial to Stock World Weekly. Click here. 

Chart by Paul Price.

...

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Option Review

Bearish Prints In DDD Put Options

3D Systems shares had been in positive territory earlier in the session, up as much as 4.2% to touch an intraday high of $50.85. The stock bounced off a low of $47.17 in the early going, a new six-month low for the share price and a more than 50% drop from DDD’s record high of $97.28 reached back on January 3rd. Shares managed to stay in the green for much of the session before succumbing to selling pressure this afternoon. Options expiring next week suggests at least one trader is positioning for further weakness in the near term.

The 17Apr’14 $47 puts traded more than 2,000 times this morning against previously existing open interest o...



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Promotions

See Live Demo Of This Google-Like Trade Algorithm

I just wanted to be sure you saw this.  There’s a ‘live’ training webinar this Thursday, March 27th at Noon or 9:00 pm ET.

If GOOGLE, the NSA, and Steve Jobs all got together in a room with the task of building a tremendously accurate trading algorithm… it wouldn’t just be any ordinary system… it’d be the greatest trading algorithm in the world.

Well, I hate to break it to you though… they never got around to building it, but my friends at Market Tamer did.

Follow this link to register for their training webinar where they’ll demonstrate the tested and proven Algorithm powered by the same technological principles that have made GOOGLE the #1 search engine on the planet!

And get this…had you done nothing b...



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Pharmboy

Here We Go Again - Pharma & Biotechs 2014

Reminder: Pharmboy is available to chat with Members, comments are found below each post.

Ladies and Gentlemen, hobos and tramps,
Cross-eyed mosquitoes, and Bow-legged ants,
I come before you, To stand behind you,
To tell you something, I know nothing about.

And so the circus begins in Union Square, San Francisco for this weeks JP Morgan Healthcare Conference.  Will the momentum from 2013, which carried the S&P Spider Biotech ETF to all time highs, carry on in 2014?  The Biotech ETF beat the S&P by better than 3 points.

As I noted in my previous post, Biotechs Galore - IPOs and More, biotechs were rushing to IPOs so that venture capitalists could unwind their holdings (funds are usually 5-7 years), as well as take advantage of the opportune moment...



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About Phil:

Philip R. Davis is a founder Phil's Stock World, a stock and options trading site that teaches the art of options trading to newcomers and devises advanced strategies for expert traders...

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About Ilene:

Ilene is editor and affiliate program coordinator for PSW. She manages the site market shadows, archives, more. Contact Ilene to learn about our affiliate and content sharing programs.

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