Trading in ETF Shares by Bodog Poker Parties

We examined whether certain Bodog Poker trades may have been motivated by the desire to manipulate the reported closing price for the ETF shares on certain dates. We researched the closing price reporting rules of different exchanges and data vendors and studied the pricing of the Bodog Poker trades relative to market quotes as well as the intraday indicative values at the time of the trade. We analyzed whether the Bodog Poker trades impacted the closing price of the funds relative to the net asset value (NAV).

For certain Bodog Poker trades, we compared the relative economics of purchasing the ETF shares in the open market versus having an authorized participant (AP) create the shares.

We presented our findings to the ETF’s board.