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Methodology

How the tests work

Download the full technical methodology (PDF, 0.9 MB)

Each test compares a member's disclosed trades with a specific signature of trading on nonpublic information. The question is always the same: does this record look more like an ordinary managed account, or like someone trading on what they know?

Four readings, not a score

Every test produces one of four readings. We do not combine them into a single probability of misconduct: the tests overlap, a single number would hide which evidence drives it, and a probability would need a prior on wrongdoing that public data cannot supply.

Fits pattern
The evidence resembles a known insider-trading signature at the stated confidence level.
Open question
The evidence is inconclusive, or it raises a compliance or conflict-of-interest concern.
Does not fit
The evidence rules out a meaningful insider-trading signature for this test.
Not assessed
Too few trades to decide either way, or the required inputs are not yet available.
Screening signal
An open question whose unadjusted p-value is below 0.05. This is weaker than a fit: across all members, about 28 such signals would appear by chance alone. It is a kind of open question, not a fifth reading, and it is never counted as a fit.

Statistical framework

Each test contrasts two explanations. Under the null, trades are chosen by a process independent of nonpublic information, so signed abnormal returns average zero and timing is unrelated to the member's information calendar. Under the alternative, some trades are timed or chosen using that information.

Equivalence as well as significance

Failing to find an effect is weak evidence when a test has little power. So each test is paired with a two one-sided tests (TOST) equivalence check against a margin δ fixed before seeing the data. With a 90% interval for the oriented parameter θ:

Reading={fitsθ^−>0 after multiplicity adjustmentdoes not fitθ^+<δopen questionotherwise\text{Reading} = \begin{cases} \textit{fits} & \hat\theta^- > 0 \text{ after multiplicity adjustment} \\ \textit{does not fit} & \hat\theta^+ < \delta \\ \textit{open question} & \text{otherwise} \end{cases}

Multiplicity

With many tests per member, and hundreds of members, some results will reject by chance. Family-wise error within a member is controlled with Holm's step-down procedure; Benjamini–Hochberg q-values are reported as a screening complement across members.

reject H(k) for k<k∗,k∗=min⁡{k:p(k)>α/(m−k+1)}\text{reject } H_{(k)} \text{ for } k < k^\ast,\quad k^\ast = \min\{k : p_{(k)} > \alpha/(m-k+1)\}

Date-clustered bootstrap

Trades on the same day share the same market shock, so intervals resample trading dates rather than individual trades, with amount imputation nested inside each replication, and use bias-corrected and accelerated (BCa) quantiles.

Power

For a mean signed abnormal return from N trades with H-day idiosyncratic volatility σ and within-date correlation ρ, the minimum detectable effect is shown below. Members with few trades get wide intervals, which usually leads to open question or not assessed rather than a false clean bill.

MDE=(z1−α/2+z1−β) σHN1+(nˉcl−1)ρ\mathrm{MDE} = (z_{1-\alpha/2} + z_{1-\beta})\,\frac{\sigma_H}{\sqrt N}\sqrt{1 + (\bar n_{\text{cl}} - 1)\rho}

Range-reported amounts

Disclosures give a value band, such as $1,001 to $15,000, never the exact amount. Every statistic carries that uncertainty in one of three ways: sharp bounds evaluated at the band endpoints (partial identification), a point estimate at the geometric midpoint for descriptive figures, and log-uniform draws inside the bootstrap for intervals.

v~i=LiUi,vi(b)=exp⁡(ln⁡Li+Ui(b)(ln⁡Ui−ln⁡Li))\tilde v_i = \sqrt{L_i U_i}, \qquad v_i^{(b)} = \exp\big(\ln L_i + U_i^{(b)}(\ln U_i - \ln L_i)\big)

The tests

Robustness

Every quantitative test is re-run with a four-factor model in place of the market model, at horizons of 5, 21 and 63 trading days, with equal and dollar weighting (the latter at both band bounds), excluding the largest batch date, and excluding spouse and dependent accounts. A reading is labelled robust only if it holds across all variants; each member's scorecard lists the variants.

Limitations

  • The tests measure resemblance to known patterns in public data. They cannot show what a member knew, and a fitting result is not a finding of wrongdoing.
  • Only disclosed trades are tested. Late, missing or misreported filings, and assets held through funds or trusts, are outside what the data can see.
  • Amounts are bands, so dollar-weighted statistics are reported as ranges or intervals.
  • Committee jurisdiction and policy-topic maps involve judgment; the maps are published with the data.

The full technical document, with every estimator, interval and algorithm, is available as a PDF download.