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THE
GOOD OLD DAYS
The
October 1987 Stock Market Crash: A Futures Market Perspective
Essay presented to the Securities Regulation Institute,
San Diego, California,
January 26, 1989.
The
annual conference of the Securities Regulations Institute represented
the inner sanctum of the securities world. Everyone of consequence
with respect to the American securities markets was in attendance.
Among those presenting their point of view with respect to
the 1987 stock market crash were David Ruder, chairman of the
Securities and Exchange Commission, John Phelan, chairman of
the New York Stock Exchange, and Joseph Hardiman, president
of the National Association of Securities Dealers.
It
was imperative that futures markets be represented and provided
an opportunity to address this forum. It was my goal to fully
present our case, lay to rest any remaining doubts about the
role of futures in the 1987 stock crash, respond to some of
the remaining issues still in controversy, and to underscore
the value of futures markets as a risk management tool in a
world substantially changed by technology and globalization.
Upon
presenting our point of view, it seemed that the two years
that had elapsed since the crash had substantially reversed
the conventional opinion about the role of futures markets.
It was clear to me from the other papers presented, as well
as from the questions we received from the audience, that the
vast majority of those present recognized that futures markets
had not been at fault in the crash—as they were originally
portrayed—and that our markets made and continue to make a
valuable contribution to the overall structure of the equity
market.

It
is inescapable: the older we get, the more we long for the good
old days. Like my contemporaries, I too have many fond memories
of days past and cannot suppress occasional daydreams reliving
those moments. Clearly, life was much more simple, music was
softer, and dancing was slower and closer. Alas, those days are
gone forever. If only one could reverse the flow of time!
The
October 1987 stock market crash occasioned a far less personal
longing for the good old days. In newspapers, in magazines, on
television, and in hearing rooms on Capitol Hill, there were
calls for a return to those halcyon days before there were stock
index futures, before program trading, before index arbitrage.
Those uncomplicated days when the average daily volume on the
New York Stock Exchange was 11.5 million shares and a good day
boasted 20 million shares; when large block transactions accounted
for 15% of reported volume as opposed to the current 50%; when
stocks were bought on the basis of your broker's assessment of
inherent individual stock values; before mutual and pension funds
complicated the financial landscape and competed for the investment
dollar with performances based on collective results or comparisons
with indexes; before such concepts as asset allocation reared
their complex heads; when fixed commissions were legal; when
globalization of markets was but a futuristic notion; before
we were so dependent upon and competed for foreign cash; before
we cared what foreign stock markets were doing and foreigners
had little impact on ours; long before LBOs, zeros, or junk bonds,
and eons before unbundled stocks.
At
the moment the crash officially ended—the moment that probers
and pundits began poking at the corpse—a belief arose that the
October 1987 stock market crash must have been caused by a specific
villain. It was, after all, unthinkable that so many successful
financial advisers who had been telling their clients to hold
on to their investment or even to buy more could possibly have
been so wrong.
Never
mind that in the words of Fed Chairman Alan Greenspan "Stock
prices finally reached levels which stretched to incredulity
expectations of rising real earnings and falling discount factors...[that]
something had to snap ... [that] if it didn't happen in October,
it would have happened soon thereafter ... [that] the market
plunge was an accident waiting to happen."(1) Never
mind that the October collapse was a global event. Never mind
that all speculative bubbles must finally burst. Never mind the
plethora of accumulating fundamental economic and psychological
factors that could trigger the collapse. Never mind all that
and let us instead search for some specific causation, some special
factor that intervened, some villainous sabotage that stopped
the six-year long bull market dead in its tracks.
And
so the search began. A bevy of studies, official and ad hoc—a
total of 77 according to SEC Commissioner Joseph Grundfest—were
launched to seek the answer to who or what did the bull market
in.
When
a demon is hunted, a demon will be found. It did not take long.
Quite soon the fingers were pointing to technology. The words
were catchy. Mindless computers were on automatic pilot. Technology
had out-distanced its effectiveness. Efficiency needs a brake
pedal! Then the search got specific: program trading. Then
even more specific: index arbitrage. All the while,
the fingers were pointing in the direction of futures.
Throughout
the process, the media—whose ability to create a public impression
has no equal—proved to be the critical medium. Because the October
crash was extraordinary and frightening, because the issues were
complex, because so many within the financial world seemed to
agree that there was a specific villain to be found, the media
generally accepted the premise at face value. That was most unfortunate,
because when the media knows little about the subject, or when
it is misdirected and there is no villain except in the minds
of those who desperately desire that there be one, it can become
a monstrous bully from which it is nearly impossible to escape.
Thus, it allowed itself to be used as the conduit of accusation
and misinformation, and sometimes even became the inquisitor
itself.
And
Congress played its part: Was there really a problem to be fixed?
Or simply an issue to be had? Either way, an investigation was
in order. An opportunity for a public forum.
And
there were those who had a special motivation to find a scapegoat.
With volume and commissions down, someone or something must be
blamed for the loss of investor confidence. Volatility became
the watch word of the day. Volatility caused lack of investor
confidence. Volatility, rather than the simple logic that after
a major market decline, only the imprudent would blindly rush
back to the market. Volatility, rather than have someone conclude
that there was a bear market about, that volume might suffer,
that jobs might be in jeopardy. Of course, volatility was just
a code word for futures-related program trading.
But
not everybody was fooled. Here is George D. Gould, former U.S.
Treasury Undersecretary for Finance:
Some
observers believe the individual investor has left the market
because of a perception of increased volatility. It is equally
possible that much of the retreat is in fact investors' collective
views that the bull market has paused or that more attractive
alternative investments are available.(2)
Nor
was SEC Commissioner Joseph Grundfest fooled when he bluntly
questioned the motives of some of those who were so anxious to
return to the good old days:
...
some participants in the policy debate have a perfectly rational
incentive to continue to confuse the message with the messenger
in order to forestall technological progress that threatens
traditional trading mechanisms that generate substantial rents
for certain market participants. Put more bluntly, some people
are making money off the system as it operates today, and measures
designed to make our markets more efficient by improving information,
expanding capacity and enhancing liquidity are not necessarily
in everyone's financial interests.(3)
Still,
witch hunting can be seductive. Indeed, the movement gained momentum
and an impressive following. It reached its zenith on May 10,
1988 when several of the most prestigious U.S. investment banking
firms bowed to nonsensical pressure and announced their withdrawal
from proprietary index arbitrage. This was to be a singularly
sad day in the annals of American finance. The movement might
have grown further except that it reached a level of near-hysteria
with a call by some for a ban on index futures. For most of the
financial community, this went too far. For most, it served as
a sudden, chilling tonic bringing them back to reality. A call
to ban was indeed too much. Wiser voices began to drown out the
prattle. Reason stepped forward.
When
I was but a young man on the floor of the old Chicago Mercantile
Exchange, long before financial futures, long before futures
became a respected and even indispensable risk management tool,
Elmer Faulkner, an old line CME member who had made and lost
many a fortune, took me by the hand. "Don't let our futures markets
get too successful," he ominously warned, waving his big cigar
in the air, "because futures markets tell the truth and nobody
wants to know the truth. And if the truth is too bad and too
loud, they'll close us down."
I
learned all too clearly how sage Elmer's advice was on October
19, 1987 when the futures index markets were the first to tell
the truth. The truth was indeed too bad and too loud.
Today,
as before the crash, the CME's Standard & Poor's 500 futures
contract is the most successful stock index futures contract
in the United States. Its success stems primarily from the fact
that it represents an equity risk management tool for the present
day and offers the most liquid and cost-efficient environment
yet devised. Success is a clear measure of merit. Despite the
clamor to ban computers and index arbitrage, futures were not
only vindicated in virtually every academic study, they received
the highest of praise from the most knowledgeable of experts.
Nor could the experts be blithely dismissed as fellow travelers
of the Chicago exchanges. Rather they were classic products of
the Wall Street community.
"What
many critics of equity derivatives fail to recognize," said Chairman
Greenspan, "is that the markets for these instruments have become
so large not because of slick sales campaigns but because they
are providing economic value to their users. By enabling pension
funds and other institutional users to hedge and adjust positions
quickly and inexpensively, these instruments have come to play
an important role in portfolio management."(4)
The
Chairman also knew why, as Elmer Faulkner said, "futures tell
the truth."
It
is also worth noting that we routinely see the futures markets
reacting to new information more rapidly than the cash markets.
Some have concluded...that movements in futures prices thus must
be causing movements in cash prices. However, the costs of adjusting
portfolio positions are appreciably lower in the futures market
and new positions can be taken more quickly. Hence, portfolio
managers may be inclined naturally to transact in the futures
market when new information is received, causing price movements
to occur there first. Arbitrage activity acts to ensure that
values in the cash market do not lag behind.(5)
Similarly,
the former U.S. Treasury Undersecretary, a man who spent better
than thirty years as a Wall Street investment banker, also knew
the truth: "Much public criticism of index arbitrage," he succinctly
stated, "is a classic case of wanting `to shoot the messenger'
that brings the bad news of selling on the CME to the floor of
the NYSE..."(6)
Why
have stock index futures become so successful? Why did Merton
H. Miller, PhD., Professor of Banking and Finance, University
of Chicago, name financial futures as "the most significant financial
innovation of the last twenty years?"(7) The
answer is clear. Our success is primarily the result of two interrelated
factors: The changed nature of the decision-making power in matters
of finance; and scientific and technological advancement. Both
factors represent trends that will not abate and which have forced
the financial world to become highly specialized and professional.
Nor
have futures markets aided and abetted institutional traders
in forcing the little guy out of the stock markets. The direct
participation of small investors as a percentage of total volume
has shrunk as the size of institutions such as pension and mutual
funds has grown. These institutions now represent the little
guy. The trend has been evident for decades and is unrelated
to program trading. It began long before the advent of futures
trading of stock indices. One set of statistics will suffice.
In the United States, investment managers now represent over
33 million mutual fund shareholders and over 60 million pension
plan participants and their beneficiaries. These funds equal
nearly $2 trillion in assets compared with only $400 billion
a mere decade ago. As a result, a myriad of specialists, techniques
and strategies have evolved. Technological sophistication has
enabled these professionals to apply their strategies with lightning
speed.
SEC
Chairman David S. Ruder, explains it well:
To
understand what happened in the U.S. securities markets in
October 1987, it is necessary to understand changes in institutional
trading strategies that took place during the last decade.
During this period, the increasing size of many institutional
portfolios made it difficult for portfolio managers to trade
in the stock of a single company without unduly affecting the
price of that stock. In addition, modern portfolio theory gained
increasing acceptance. As a result, many portfolio managers
began to shift emphasis from individual stock selection toward
trading the market as a whole.(8)
Consequently,
says Mr. Gould, "stock index futures markets have evolved
as the lowest cost, most efficient response to these changed
needs. "`Trading the market' and hedging are not in and of themselves
either good or bad — they are economic facts that are not going
to go away."(9)
Unfortunately,
traditional market mechanisms were not structured to accommodate
the massive and sudden money flows these managers now command.
Until recently, the technological disparity between markets and
their participants was growing. On October 19, 1987, we learned
the extent of the foregoing truth in a very real and painful
fashion.
Again
the Fed Chairman summed it up well when he recently asserted
that "the severity of the crash of October 19, 1987 was in a
sense the outcome of a confrontation between dramatically advancing
computer and telecommunications technology on the one hand and
ingrained human speculative psychology on the other."(10)
Of
all the undeserved missiles directed at futures during the witch
hunt, the two I found particularly unfair were the call for a
single regulator and for higher futures margin—as if these issues
were factors in the crash or could prevent the next one. Proponents
of such views were wrong. As far as the crash is concerned, such
issues were classic red herrings. At best they were a knee-jerk
reaction based on misunderstanding and misconceptions about futures;
at worst they were much more disconcerting.
Dr.
Alan H. Meltzer, the John M. Olin Professor of Political Economy
and Public Policy at Carnegie Mellon University, who participated
in a study of the crash by the Mid America Institute for Public
Policy Research, finds no evidence to support efforts for any
new futures legislation. Indeed, he suggests that a very likely
reason for the hullabaloo in Washington was that the October
crash created an opportunity for the SEC to gain at the expense
of the CFTC. While he recognizes that this explanation may sound
somewhat cynical, he finds no other rationale that is consistent
with the behavior of those who sought more regulation.
"Higher
margin requirements on futures," states Dr. Meltzer, "and restrictions
that make options and futures more costly, if accompanied by
the proposed new rules to permit portfolios to be traded in New
York, would shift trading and commissions from Chicago to New
York."(11)
While
I personally never subscribed to so extreme a view, I do sympathize
with Dr. Meltzer and others who were bewildered by demands for
change in federal regulatory or margin jurisdiction without any
fundamental evidence that these issues were a factor in the 1987
crash.
In
his October 20th paper, after complimenting the CME for raising
its initial speculative margins after the crash, Chairman Ruder
questioned the fact that the CME subsequently lowered the hedge
margins. First, I would ask the Chairman to examine the history
of this issue. He will find that margins in securities options—competitive
products to the CME index futures over which the SEC has jurisdiction—were
lowered before the CME took the action of which he complains.(12)
Second,
I would point out that the findings of the Presidential Working
Group—of which Chairman Ruder was a member—concluded that "...the
prudential maintenance margin percentages required for carrying
an individual stock should be significantly higher than the percentage
margin required for a futures contract on a stock index. This
conclusion follows from the facts that stock indexes have a smaller
percentage price variability than do individual stocks and the
payment period for margins in the futures market is shorter than
the period for stocks."(13)
The
differences between the role, function and level of futures and
stock margins exist as a natural and necessary result of the
very different functions these two markets perform. They are
not the result of a regulatory gap or loophole. Foreign futures
markets that compete directly with our American futures markets
for world business understand and apply the aforestated different
standard between securities and futures margin. Allow me to call
attention to this conclusion of Chairman Greenspan upon issuing
the Working Group Report:
...I
believe that we should not be guided in the margin area by
equalization for leveraging reasons. Implementing such an approach
would only tend to give rise to a false sense of security about
price movements at a time when, given the underlying economic
setting and fundamental change in the structure of the equity
markets, price movements may well remain larger than we had
come to expect in earlier years. Raising margins will add indirectly
to transaction costs, which will act to reduce trading volume
and market liquidity...(14)
In
view of these compelling findings, the Options Clearing Corp.
should be commended for leading the charge in lowering their
margins. The belief that futures and options margins must somehow
be "harmonious" with securities margins is not only unfounded,
it runs contrary to the Working Group's enunciated conclusion
that they instead need to be "prudential." This conclusion takes
on even greater relevance based on the fact that today's market
volatility has been reduced by a factor of four. (Volatility
during the July to December time period in 1987 was measured
at 59.45%, while for the same period in 1988 it was 13.58%. Even
discounting the volatility of the week of the crash itself, volatility
for the second half of 1988 was 49.6% less than the second half
of 1987).
If
our markets remain chained to the onerous margin policy demanded
by some in the wake of the crash, it would do precisely as the
Fed Chairman warned: "add indirectly to transaction costs and
act to reduce trading volume and market liquidity." This would
damage the economy as a whole and materially frustrate our ability
to compete internationally. Ultimately, it would impede the favorable
flow of business resulting from this American invention and,
like the Eurobond market of a previous era, lose this vibrant
economic activity to a foreign competitor. It is high time to
slay this mythical margin monster.
Similarly,
it is time to put the idea of a single regulator for all financial
markets in its proper perspective. The idea is not new, and while
it can be debated from various viewpoints, it has no relevance
to the October 1987 crash. Its latest thrust stemmed from the
Brady Report which correctly identified the "one-market" nature
of the financial marketplace. However, the one-market premise
incorrectly led the Report to the concept of a single regulator,
albeit, in this case, that regulator—the Federal Reserve Board—would
be responsible only for certain inter-market matters.
Daniel
R. Fischel, Director, Law and Economics Program, University of
Chicago, who analyzed the Brady Report with respect to this issue,
forcefully dismisses the one-agency concept by concluding that
the logical premise for such a proposal is erroneous. "There
is not one shred of evidence in the entire Brady Report," Professor
Fischel declares, to suggest that regulatory failure produced
or exacerbated Black Monday. Furthermore, he argues, there is
no evidence to imply that competition among regulators is harmful,
nor that regulatory cooperation, when desirable, cannot occur
without a single agency. Indeed, he too questions the economic
theory motivating the one-agency proposal, "given the proposal's
lack of rationale."(15)
Concurring
with the foregoing view is SEC Commissioner Edward Fleischman
who points out that the fundamental differences between securities
and futures are sufficient reason not to give the SEC
regulatory jurisdiction over financial derivative products. He
too concludes that regulatory competition is "an extraordinary
healthy development...[which is]...beneficial to both regulators."(16)
At
this juncture it is perhaps important to explode one or two other
false assumptions that became commonplace in the aftermath of
the crash, as well as to underscore the principal differences
and similarities between securities and futures.
It
cannot be said better than did The Federal Reserve Bank of Chicago,
in its paper published May 1988:
At
the heart of the economic role of a futures market is risk
transfer. Futures contracts provide a way of transferring risk
from hedgers who seek to reduce risk to speculators who would
bear risk in the hope of profiting by it. Attempts to curb
speculative activity on these contracts by raising futures
margins overlook the fact that such curbs would also reduce
an investor's ability to sell off unwanted risk by hedging.(17)
Allow
me also to emphasize that many of the benefits to society resulting
from futures are similar to the benefits resulting from the stock
market. Both markets play an analogous role in our nation's capital
formation process. By providing institutional investors with
a vehicle for transferring the risk of a stock portfolio, and
by providing liquidity for "baskets" of stock, the futures
market increases the attractiveness of equities as an investment
and thereby encourages capital formation.
Such
benefits are stressed by Professors Hans R. Stoll and Robert
E. Whaley in their 1988 study of stock index futures and options.
Futures and options markets, they assert, "are useful portfolio
management and hedging tools enabling inventories and cash flows
to be hedged, enabling security analysts to concentrate on stock
selection while avoiding general market risk, facilitating market
timing, asset allocation and dynamic hedging, and permitting
a division of responsibilities among portfolio managers."(18)
In
responding to some of the more assaulting accusations levelled
against futures, it is unnecessary to go much beyond the exhaustive
study of the 1987 crash by Professor Richard Roll, Allstate Professor
of Finance, University of California at Los Angeles. His conclusions
typify those reached in virtually every other academic study.
That
the crash was a global event and that the United States market
was not the first to decline sharply nor did it decline the
most. In a comparison of the October declines (on the
basis of local currency) of 23 stock markets around the world,
the U.S. had the fifth smallest decline; i.e., the
fifth best performance. Since the U.S. was the only country
with a highly developed index futures market, Professor Roll's
conclusion goes a long way in nullifying the notion that these
derivative markets were somehow a cause of the crash.
That
there is virtually no evidence to support the view that the
institutional structure of the U.S. market was somehow the
culprit of the crash. "Automated quotations," states
Professor Roll, "forward trading, transaction taxes, limits
on price moves, and margin requirements all had no perceptible
influence on the extent of the crash." Moreover, he argues
convincingly that the global nature of the crash "debunks the
notion that some basic institutional defect in the U.S. was
the cause..."
That
computer-directed trading such as portfolio insurance did not
exacerbate the crash. Indeed, in local currency terms,
the average decline of five countries in which computer directed
trading is prevalent (Canada, France, Japan, the U.K. and the
U.S.) was 6.6 percentage points less than the average decline
of the 15 countries where it is not prevalent. Consequently,
if such strategies had any impact at all, they actually helped
mitigate the market decline.
That
in an examination of ten characteristics empirically associated
with the extent of the price decline, options and futures trading,
were unrelated to the extent of the crash.(19)
As
in every storm there is a silver lining. The crash became the
catalyst for action long overdue. It prompted a realistic appraisal
of market mechanisms that had fallen far behind current needs,
it precipitated an analysis of the type of instruments necessary
to serve present day transaction demands, and it resulted in
a recognition that index futures are an indispensable and integral
component of today's market structure. The process was difficult
and exasperating, but in the end it effected perhaps one of the
finer cooperative accomplishments within the private sector in
recent memory.
While
the measures instituted and the ones yet to come are imperfect
and cannot guarantee that there will not ever be another crash,
they have gone a long way to insure that the securities and futures
markets do not disfunction during a panicked downswell and that
critical financial safeguards have been implemented. These initiatives
conform with current financial market needs as well as the recommendations
of the Presidential Working Group and the Brady Commission. Briefly,
they cover the following areas: the establishment of industry-wide circuit
breakers (coordinated procedures and market halts for the
U.S. securities and futures markets during any drastic drop in
prices); coordinated shock-absorbers between the NYSE
and CME; enhanced and updated CME clearing operations and risk
management systems; establishment of a permanent financial surveillance
group—comprised of the securities and futures exchanges and their
clearing organizations—for the purpose of sharing of financial
information and joint audits; enhancement of inter-exchange communications
respecting market information and exchange actions that affect
other markets; and the broadening of the scope of the SEC-initiated
Inter-Market Surveillance Group.
The
stock market crash of 1987 provided clear and convincing evidence
that market globalization was upon us. The world is increasingly
becoming smaller. What were once dozens of scattered national
economies are inexorably becoming linked into one global economy.
The telecommunications revolution wrought by sophisticated satellites,
micro-chips and fiber optics has changed the world from a confederation
of autonomous financial markets into one continuous global marketplace.
In this global economy, money managers and traders no longer
have the luxury of reserving investment decisions until local
markets open. When a President or Prime Minister delivers a speech,
holds a press conference, or in some way articulates a shift
in policy, news of the pronouncement is flashed around the world.
Within seconds, traders have the ability to translate this information
into market action with a simple keystroke. Thus capital follows
the sun, seeking out investment or risk management opportunities
regardless of geographical boundaries or time zones.
Futures
markets were first to respond to this reality. Two decades ago,
the presence of a stock exchange and a large bank was the accepted
benchmark for a city to be considered a financial center. Today,
as we have seen from the investor's growing dependence on financial
futures contracts, a true financial center must have a futures
exchange as well.
Foreign
financial centers had no problem accepting this view or understanding
the value of index futures. Even as the U.S. deliberated the
role of futures in the October 19 market collapse, the London
International Stock Exchange published its conclusion that the
solution was in more, not less, index arbitrage. At the same
time, in Japan, the Ministry of Finance did not hesitate to announce
its decision to establish not one, but two index futures markets—the
Nikkei 225 at the Osaka Securities Exchange and the TOPIX at
the Tokyo Stock Exchange.
Our
community, however, as Elmer Faulkner predicted, has become afraid
of the truth. Rather than face a complex and often painful reality,
we would embrace a seemingly painless myth, or attempt to turn
the clock back to a less complicated, less global world of two
decades before. We are easily led to seek legislative solutions
in an attempt to return to a less competitive past. Without question,
reality is less quaint and usually less fun than nostalgia. However,
what everyone invariably forgets about the good old days is that
back then, if the market dropped 508 points, it was back to zero.
____________________
(1) Alan
Greenspan, Chairman, Federal Reserve Board of Governors, Testimony
before the U.S. Senate Committee on Banking, Housing and Urban
Affairs, February 2, 1988, p. 13.
(2) George
D. Gould, Treasury Undersecretary for Finance, Testimony before
the U.S. House Subcommittee on Telecommunications and Finance
of the Committee on Energy and Commerce, May 19, 1988, p.
4.
(3) Joseph
A. Grundfest, Commissioner, Securities and Exchange Commission, "Would
More Regulation Prevent Another Black Monday?" Cato Policy
Report, September/October 1988.
(4) Alan
Greenspan, Chairman, Federal Reserve Board of Governors, Testimony
before the U.S. House Subcommittee on Telecommunications and
Finance of the Committee on Energy and Commerce, May 19,
1988, pp. 4-5.
(5) Ibid.,
p. 8.
(6) Gould, Testimony,
May 19, 1988, p. 8.
(7) Merton
H. Miller, Financial Innovation: The Last Twenty Years and
the Next, Graduate School of Business, The University of
Chicago, Selected Paper Number 63, May 1986.
(8) David
S. Ruder, Chairman, Securities and Exchange Commission, "October
Recollections: The Future of the U.S. Securities Markets," October
20, 1988, p. 1.
(9) Gould, Testimony,
May 19, 1988, p. 5-6.
(10) Alan
Greenspan, Chairman, Federal Reserve Board of Governors, Joint
meeting of the American Economic and the American Finance Associations,
New York, December 28, 1988.
(11) Allan
H. Meltzer, John M. Olin Professor of Political Economy and Public
Policy, Carnegie Mellon University, "What Really Happened in
the Crash," Corporate Finance, August 1988, p. 8.
(12) The
Chicago Mercantile Exchange lowered S&P 500 stock index futures
hedge margins at the close of business on September 21, 1988.
The Options Clearing Corporation lowered S&P 100 equity options
margins on September 19, 1988.
(13) Interim
Report of The Working Group on Financial Markets, Submitted
to The President of the United States, May 1988.
(14) Greenspan, Testimony,
May 19, 1988, p. 12.
(15) Daniel
R. Fischel, Director, Law and Economics Program, University of
Chicago, "Should One Agency Regulate Financial Markets?" Black
Monday and the Future of Financial Markets.
(16) Edward
Fleischman, Commissioner, Securities and Exchange Commission,
Address before the Commodities Law Institute, Chicago, Illinois,
October 21, 1988.
(17) Herbert
L. Baer, Maureen V. O'Neil, Chicago Fed Letter, The Federal
Reserve Bank of Chicago, May 1988, p. 1.
(18) Hans
R. Stoll, Owen Graduate School of Management, Vanderbilt University
and Robert E. Whaley, Fuqua School of Business, Duke University, Stock
Index Futures and Options: Economic Impact and Policy Issues,
January 1988, p. 31.
(19) Richard
W. Roll, Allstate Professor of Finance, University of California,
Los Angeles, "The International Crash of October 1987," Black
Monday and the Future of Financial Markets.
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