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.

Comments

Good idea.

[T-Bucket]

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...

Re:Good idea.

[MrNaz]

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.

Is nobody else flashing back

[troff]

... 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.

Re:Sounds silly to me

[jmcvetta]

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.