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 | — | settled |
| SEC v. Chatham Asset Management, LLC and Anthony Melchiorre (benchmark submission rigging, 2023) | SEC | 2023-04-03 | Benchmark Submission Rigging | $600k | settled |
| SEC v. The Bancorp, Inc. (benchmark submission rigging, 2022) | SEC | 2022-08-24 | Benchmark Submission Rigging | — | 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 |