On the First Day of Christmas, MF Global Documents Disappeared from the SEC's Public EDGAR Database

Say what you will about the Securities and Exchange Commission's approach to regulating the capital markets, but at least we can sleep soundly under the warm blanket of integrity that is its Electronic Data Gathering And Retrieval (EDGAR) system--that internet portal available to all, which maintains the financial reporting and related documents of tens of thousands of entities that transact business in the US capital markets. Or can we?

While the more commonly referenced files on EDGAR, such as public company annual 10-K's and quarterly 10-Q's, are fully digital and searchable, some filings are simply scanned from hard copies. While often overlooked, these documents, such as the annual audited financials of broker-dealers, can yield precious insights relevant to their parent holding companies.

For instance, we wrote shortly after MF Global's bankruptcy that the last audited financials of the broker unit, MF Global Inc., revealed many more details about the famed European debt repo-to-maturity trades than were disclosed in its parent's filings. Not the least of which was that the trades were with an affiliate on terms to the derogation of the broker customers. Eighty percent of the profits were shipped to the affiliate, while ALL risk remained at the broker unit (see Note 11 to the financial statements embedded at the end).

It was while searching for this very filing recently that were were confronted with a giant Orwellian sucking sound--for the downloadable PDF link from the EDGAR reference page had simply been removed.

First, see the filing for the year ended March 31, 2010, which is still intact [click any image in this post to enlarge].:

While it's common to see the "File Date Changed" not match the actual "Filing Date", it is usually quite close. The middle download link labelled "scanned.pdf", will produce the actual report. The other two links merely contain electronic header information.

Now see the March 31, 2011 filing:

Note the obvious omission of the "scanned.pdf" line, as well as the recent "Filing Date Change"--to December 14, 2011. Only the header links remain. Interestingly, the URL of the PDF that we had posted in early November (prior to the redaction) is still valid, but likely not for long. For the historical record of EDGAR database changes at the SEC has been one of permanent deletion.

Up next, Banc of America Financial Services, Inc. (now owned by BNP Paribas), vintage year-end 2007, which you might remember from such themes as, the sub-prime and equities peaks, as well as the great August quant blowout:

Remember when Goldman Sachs transformed itself nearly overnight from a mere broker to a bank holding company vis a vis an emergency order from the Federal Reserve in late 2008? The broker unit changed its reporting month to calendar year end (from November 30) along with its holding company, such that its financials ended 2009 would contain thirteen months. The audit of the broker until would be filed March 1, 2010, but an amendment was filed only two days later. It is this very amendment that has also been forwarded to dev/null.

That was a good week in 2010 for deleting amendments, because that would also be the fate of J.P. Morgan Securities Inc., the inheritor of the Bear Stearns broker.

And what would a collection such as this be without Refco Securities LLC?

Yes, the "scanned.pdf" link is there, but if one examines the PDF, all that is present is the cover section--absolutely no financial data. Inasmuch as the "Filing Date Changed" is over six months from the "Filing Date", we are left to wonder if a redacted version was simply slipped in toward the end of 2004 (which, incidentally, is when the company was preparing for its fraud-laced IPO).

For what it's worth, the MF Global Inc. financials for the year ended March 31, 2011 can still be found here:

mf global audit - 9999999997-11-014930