Slashdot Mirror


SEC Proposes Wall Street Transparency Via Python

An anonymous reader writes "A US federal agency is considering the use of computing languages to specify legal requirements. 'We are proposing that the computer program be filed on EDGAR in the form of downloadable source code in Python. ... Under the proposed requirement, the filed source code, when downloaded and run by an investor, must provide the user with the ability to programmatically input the user's own assumptions regarding the future performance and cash flows from the pool assets, including but not limited to assumptions about future interest rates, default rates, prepayment speeds, loss-given-default rates, and any other necessary assumptions.' Does this move make sense? If the proposed rule is enacted, it certainly will bring attention to Python or other permitted languages. Will that be a good thing?" The above quotes were pulled from pages 205 and 210 of the dense, 667-page proposal document (PDF). Market expert and professor of finance Jayanth R. Varma says it's a good idea.

32 of 278 comments (clear)

  1. Good idea. by T-Bucket · · Score: 5, Funny

    I think a lot of those wall-street types would suddenly admit to everything they've done wrong if you confront them with a big enough Python...

    1. Re:Good idea. by MrNaz · · Score: 5, Interesting

      You say that jokingly, however, your point is rather poignant. If Wall Street types were presented with a way to transmit their methods and assumptions in a non-human readable way like a programming language, it becomes less transparent, not more. Sure investors can say "if a, b and c, then something happens in this black box and outputs x, y and z". They have no idea how their assumptions lead to the given result.

      My view is that there just is no substitute for a system of social morality like those in eastern cultures of old. Modern society has the attitude that "if it's not illegal, do it". Unfortunately, the law will never be able to codify in black letters the rich spectrum of behavioral regulations imposed by morality, developed over thousands of years of human behavior. Thus, individuals conforming only to the law and ignoring ethics and morals will inevitably breach their moral duty, and the damage they do is limited only by their "creativity" in using the law and the social power they weild due to their position, wealth or influence.

      In short, we need to disabuse ourselves of this trend to consider ethics and morals some hokey, freedom-fettering construct that has become obsolete. It is very much necessary, and Wall Street is a great place to look if you want an example of why.

      --
      I hate printers.
    2. Re:Good idea. by TapeCutter · · Score: 4, Funny

      I think a lot of those wall-street types would suddenly admit to everything they've done wrong if you confront them with a big enough Python...

      Considering the amount of snake oil on Wall street, I think the python would be the one begging for mercy.

      --
      And did you exchange a walk on part in the war for a lead role in a cage? - Pink Floyd.
    3. Re:Good idea. by TapeCutter · · Score: 4, Funny

      "My view is that there just is no substitute for a system of social morality like those in eastern cultures of old."

      Yeah, Atilla the hun was a real sweetheart.

      --
      And did you exchange a walk on part in the war for a lead role in a cage? - Pink Floyd.
    4. Re:Good idea. by Eivind · · Score: 3, Insightful

      Better yet: If you do not understand an investment, don't buy it.

      Really. There's no shortage of investments that are *easy* to understand, and the lack of free lunches means that investments you -don't- understand, tend to come with drawbacks that are invisible to you, because you don't understand them.

      What's wrong with: "Buy 100 shares of a company with a total of 1M shares, if the company pays a dividend, you get 100/1M of it, if the company goes broke, your investment is lost. There's a $5 fee for the purchase, but other than that no fees or associated costs whatsoever"

      Too simple ?

  2. Ugh! by oldhack · · Score: 3, Insightful

    Now, in addition to lawyers and accountants, you need computer programmers to invest. This smells like a racket. On the other hand, it can't get any worse than the legalese, and maybe that is the point.

    --
    Fuck systemd. Fuck Redhat. Fuck Soylent, too. Wait, scratch the last one.
    1. Re:Ugh! by MrNaz · · Score: 3, Interesting

      The average consumer cannot understand cell phone contracts, gym membership contracts, car lease contracts, bank account terms and conditions and a whole bag of other things. So you're saying they should abstain? Hell, I cant get a parking voucher from an underground car park these days without the back of it being covered in fine print you'd need a scanning electron microscope to read.

      No sir, the answer isn't to "vote with your dollar". It's to acknowledge that the entire social system is broken and massively favors big money interests that are in a position to use the legal system to their own ends.

      The fix is not some new piece of regulation you can come up with. You'll never be able to legislate around a population's total lack of ethics.

      --
      I hate printers.
  3. Fantastic! by nhaines · · Score: 4, Interesting

    This would be a fantastic idea. Not only would the rules be transparent and non-ambiguous, but the potential for experimentation and self-analysis would be incredible. Python is definitely one of the better languages to use for this, as it tends to be very readable and self-explanatory as far as programming languages go.

    1. Re:Fantastic! by DeadDecoy · · Score: 3, Informative

      By that same measure, it's not impossible to obfuscate python. If there's enough money involved, you can bet an innocuous hack will be coded in there somewhere.

    2. Re:Fantastic! by Areyoukiddingme · · Score: 4, Funny

      Pass your object to her method and see if it executes...?

    3. Re:Fantastic! by Eivind · · Score: 4, Interesting

      A fantastic idea ! Furthermore, have it online. Furthermore, put the data that the govt gets anyway into the forms so that they're partly pre-filled. Indeed, do what we've done in Norway for a decade.

      By now it's progressed to the point where I can -literally- file my taxes from my mobile phone in 15 minutes. And it takes that long only because my investments are semi-complex (i.e. some of them are foreign so don't come pre-filled)

      Oh, and yeah, it does mean you know how much taxes you owe instantly, after you fill in the forms, you press "calculate taxes", and up pops the answer, none of that file paperwork, wait months for the response.

  4. Computational Bureaucracy??? by flajann · · Score: 4, Funny

    I love Python and I would hate to see it abused this way.

    1. Re:Computational Bureaucracy??? by ron-l-j · · Score: 3, Funny

      Please do not teach any lawyers anything about Python. What is left in readability would be destroyed.And they would go on to other languages like Perl, Now that's a lawyers language :D We will have to make a new language for them call black and white. Where any gray terminology is a syntax error.

  5. hmm by bigattichouse · · Score: 3, Interesting

    Maybe if the languages accepted are functional, and therefore logically provable without side-effects.

    --
    meh
  6. Good Idea by BabyDuckHat · · Score: 3, Insightful

    If you want to confront the devil, a programming language is a good place to do it, since it's all about the details.

    1. Re:Good Idea by matrim99 · · Score: 3, Funny

      In this case, one could say "The devil is in the indentation."

      --
      Right. No, your other right. No, the other other right.
  7. This proves that... by cosm · · Score: 3, Interesting
    even in legal/financial-speak summaries...

    downloaded and run by an investor, must provide the user with the ability to programmatically input the user's own assumptions regarding the future performance and cash flows from the pool assets, including but not limited to assumptions about future interest rates, default rates, prepayment speeds, loss-given-default rates, and any other necessary assumptions.'

    ...it is forbidden to have a straightforward sentence with less than two conjunctions.

    --
    'We are trying to prove ourselves wrong as quickly as possible, because only in that way can we find progress.' RPF
  8. Re:its a step in the right direction by Monkeedude1212 · · Score: 3, Funny

    Well, Yeah, but to make a dollar, the code is just

    Print "$1.00"

  9. Filing Agents by geekmansworld · · Score: 3, Interesting

    Something that needs to be considered is the existence of so called "Filing Agents". I work for such a business.

    Right now, the SEC requires companies to file documents in a specific subset of HTML, as well as (in some cases) XBRL, which is an XML-based reporting language. In some rare cases, documents are another type of XML, or even specially formatted ASCII documents (ugh).

    Securities lawyers and company administrators don't want to understand the highly technical processes involved, so they outsource their technical reporting requirements to filing agents. We take care of all the nitpicky details that they don't want to consider. Looks like we'll have to learn Python as well. We've been meaning to graduate from Perl anyway, so no big deal. :-)

  10. Rule 1291.3120-b-Clause 32 Section 1.1 by cosm · · Score: 3, Funny

    Occam's Razer does not apply to matters of finance. Ever.

    --
    'We are trying to prove ourselves wrong as quickly as possible, because only in that way can we find progress.' RPF
  11. No OOP by Cryacin · · Score: 4, Funny

    Just remember that one instance of the class of person may never touch another instance of the class of person's privates. You need to use protected for that.

    --
    Science advances one funeral at a time- Max Planck
    1. Re:No OOP by spazdor · · Score: 3, Funny

      Well, depending on the language, sometimes you can shortcut access to the other person's privates using 'friend' functions.

      --
      DRM: Terminator crops for your mind!
  12. Re:Investors are already making their own assumpti by modmans2ndcoming · · Score: 4, Insightful

    actually... they were selling a car with no brakes... claiming it is safe, then taking out a life insurance policy on the sucker they sold it to.

  13. Is nobody else flashing back by troff · · Score: 5, Interesting
    ... to Charles Stross's flash-forward from "Accelerando"?

    "My name is Alan Glashwiecz, of Smoot, Sedgwick Associates. Am I correct in thinking that you are the Manfred Macx who is a director of a company called, uh, agalmic dot holdings dot root dot one-eight-four dot ninety-seven dot A-for-able dot B-for-baker dot five, incorporated?"

    "Uh." Manfred blinks and rubs his eyes. "Hold on a moment." When the retinal patterns fade, he pulls on his glasses and powers them up. "Just a second now." Browsers and menus ricochet through his sleep-laden eyes. "Can you repeat the company name?"

    "Sure." Glashwiecz repeats himself patiently. He sounds as tired as Manfred feels.

    "Um." Manfred finds it, floating three tiers down an elaborate object hierarchy. It's flashing for attention. There's a priority interrupt, an incoming lawsuit that hasn't propagated up the inheritance tree yet. He prods at the object with a property browser. "I'm afraid I'm not a director of that company, Mr. Glashwiecz. I appear to be retained by it as a technical contractor with non-executive power, reporting to the president, but frankly, this is the first time I've ever heard of the company. However, I can tell you who's in charge if you want."

    "Yes?" The attorney sounds almost interested. Manfred figures it out; the guy's in New Jersey, it must be about three in the morning over there.

    Malice – revenge for waking him up – sharpens Manfred's voice. "The president of agalmic.holdings.root.184.97.AB5 is agalmic.holdings.root.184.97.201. The secretary is agalmic.holdings.root.184.D5, and the chair is agalmic.holdings.root.184.E8.FF. All the shares are owned by those companies in equal measure, and I can tell you that their regulations are written in Python. Have a nice day, now!" He thumps the bedside phone control and sits up, yawning, then pushes the do-not-disturb button before it can interrupt again. After a moment he stands up and stretches, then heads to the bathroom to brush his teeth, comb his hair, and figure out where the lawsuit originated and how a human being managed to get far enough through his web of robot companies to bug him.

  14. Huh- why? by nuggz · · Score: 3, Interesting

    So rather than actually explain what the item is, they'll just build a model of what it is, and let you put in your own assumptions.

    So we'll create a bunch of programming overhead, and end up with huge improvements.
    Namely that iInstead of descriptions nobody reads or understands, we'll have programs nobody runs or understands.

    I've got an idea, I know it might sound crazy but here it goes.
    If you see someone selling a great deal, but you don't quite get what they're selling, how it works, or even why it's such a great deal, DON'T BUY IT.

    We could even impose this on industry, maybe make it a legal/ethical requirement that people moving around large sums of money act with due diligence or something.

    If people actually stuck to this, and only bought things that they understood and made sense to them, the companies making these confusing products that nobody understands would have to make simpler more straightforward products.

    These guys need to step back, and make products that THEY understand. If the designer of the product can't figure it out, it's too confusing. If none of the potential customers can understand it, it's too confusing.

    Really if they currently can't implement the description, how does documenting it in python make it any better?

    1. Re:Huh- why? by ZachPruckowski · · Score: 3, Insightful

      The problem this solves is a financial company's tendency to say "the model predicts this complex asset has a value of $Money" without explaining the model and its assumptions. Forcing them to show you the model lets you decide how much you think the asset is worth, and how full of crap the bank is. I'm sure if you asked in 2009, many banks had the modeled value of sub-prime mortgage derivatives at like 50 cents on the dollar or something, because they built their models to show a value that wouldn't make them bankrupt, instead of a more realistic value like 10 cents/dollar. This regulation would make it easier to call them on that stuff.

  15. More appropraite Legalese by thoughtspace · · Score: 4, Funny

    > cat test.legalese

    The said variable 'i' hereafter referred to as "i" shall be a variable and not of unvarying or constant except for the purposes of using the said variable within a clausal computation and shall be initially equated to 1 (one) neither less nor more and "i" shall be displayed to a third party within visual distance from the visual display device but not beyond unless further provision is granted and provided by the creator of the said work. These courses of action shall be repeated for 10 (ten) times neither more nor less withstanding any systemic error which may cause the premature termination of the said operations and includes the increment of "i" by 1 (one) in a positive monotonic uniform manner performed prior to each display to the visual display device. Upon termination of the aforementioned operational sequence the operations shall cease until recommenced upon instruction of the operator.

    > glegalese test.legalese
    > a.out
    1
    2
    3
    4
    5
    6
    7
    8
    9
    10
    >

  16. Sounds silly to me by cdrguru · · Score: 3, Insightful

    OK, how about if instead of providing mileage ratings that car advertisements simply had a URL to a Python program that if you entered information about your driving habits that it would come out with an MPG value for a specific car. Obviously, there would be a completely separate Python program for every single car.

    Of course, 99% of the weighting would be handled by the questions "Do you drive with a lead foot?" and "Are jackrabbit starts your normal mode?" But the other 34 questions would be there as specified by the government regulation governing the production of these Python applications.

    Having a model and the user gets to make up the assumptions, you are getting a traditional garbage-in, garbage-out algorithym. Any model can conform to any belief system given the "proper" inputs. Isn't this half of what the climate arguments are about? Not the code, but the assumptions being pushed into the model?

    I can't imagine that this would provide the average Joe Sixpack any useful information. I would say this isn't "transparent" in any way - unless the inputs to the model were published and required to be adhered to. This would make legally binding assumptions like in 2050 there will be fewer literate people than in 2000. I'd like to see the government come up with a plan for that.

    Or worse, if a fundamental assumption of the model is rising interest rates and every investor makes 100% return in five years, great. Does the ability to push out a program that says if you enter the five year interest rates as steadily rising then justify advertising that every investor will make 100% of their money?

    This also reeks of the idea that if you can't read a programming language you are a second-class citizen. Richard Stallman would be proud.

    1. Re:Sounds silly to me by jmcvetta · · Score: 5, Insightful

      I can't imagine that this would provide the average Joe Sixpack any useful information.

      Joe Sixpack doesn't typically buy collateralized debt obligations. In fact, if he bought a tranche of a CDO, I think that would immediately disqualify him from his everyman status. The main customers for these sometimes obscenely complex instruments are investment firms.

      Problem is, the legalese is so dense, even professional investment analysts have a hard time understanding the payout scheme. If I understand the proposal correctly, the Python code will itself authoritatively define the flow of funds from the investment vehicle. It won't simply be a model that makes predictions based on initial assumptions -- it will also "allow the use of the proposed asset-level data file that will be filed at the time of the offering and on a periodic basis thereafter". Thus given specific data about the performance of underlying assets up to any given point, the code will spit out an authoritative answer of "who gets paid what (if anything)".

      Since a structured investment vehicle is essentially an algorithm wrapped in a contract, it makes sense to use a programming language to specify that algorithm. I personally like Python; but I agree with other posters who have said the regulation should ensure that other languages can be added over time.

  17. Re:its a step in the right direction by ianare · · Score: 4, Insightful

    That's a good point to make, though I think your estimate of 5 years does little justice to Python. Regardless, the problem with NOT specifying a language is that it means I can make my own proprietary language and release that source code (and not the compiler, say).

    Also, Python is open source through and through : community developed, open specs, several open source implementations. This means that even if one day 25 years from now Python is a dead language as far as practical usage goes, it will be no harder to understand and execute as it is today.

  18. Re:Python's readability makes it a good choice by poopdeville · · Score: 3, Insightful

    What is the difference in Gambling and Investing?

    Whether the odds are with you or against you.

    --
    After all, I am strangely colored.
  19. Re:its a step in the right direction by timeOday · · Score: 3, Insightful

    The problem with mandating a particular language(s) is that these are subject to change with time. A legal framework should stand the test of time, and thus not include requirements for "Python". Python might not exist in five years, or may become obsolete in five years.

    You could say the same for English, since it changes constantly. Then again, English never had well-defined syntax or semantics in the first place...

    One reference language is a far better choice than a whole slew of them. To much unnecessary flexibility just adds complexity. Even if mainstream Python went in a different direction, the legally mandated dialect would survive for that purpose.