29 June 2017

Securities: FMA v. Warminger

A five-year ban from securities trading and a $400,000 fine followed Mark Warminger’s market manipulation of shares in Fisher & Paykel Healthcare and a2 Milk.  He could not claim any reduction in his fine for the $1.1 million penalty paid earlier by Milford Asset Management when accepting responsibility for failing to properly supervise Warminger’s trading.
Before Warminger’s trial, Milford Asset Management Ltd pleaded mea culpa negotiating a settlement with the Financial Markets Authority.  Warminger was found liable following a High Court trial for creating a false market in both a2 and Fisher & Paykel shares in mid-2014.
Warminger said he should get credit for Milford Asset’s payment against any fine imposed on him personally.  The Securities Act imposes fines totalling either three times the benefit gained/loss avoided or the value of the transaction itself.  Justice Venning ruled the maximum fine Warminger faced was $3,845,900; the value of the impugned transactions.  Warminger said the Fisher & Paykel transaction generated a gross profit of no more than $16,000.  The a2 transactions were in effect a loss; shares were bought unnecessarily on-market at a higher price than off-market offers in attempts to force up the price.
Justice Venning ruled Warminger could not claim the benefit of Milford Asset’s payment.  When trading, Warminger was acting “for” Milford on behalf of its clients.  He was not then acting “as” Milford in executing trades.  Milford Asset’s payment was not in mitigation of Warminger’s market manipulation; it was punishment for the lack of internal controls which left Warminger inadequately supervised.
Justice Venning ruled the appropriate starting point was a $500,000 fine.  This was reduced by $100,000 for the fact Warminger was now effectively barred for life from securities trading and was presently unable to undertake meaningful employment because of medical conditions disclosed to the court.  A criminal conviction, rather than Securities Act liability, would have exposed Warminger to a potential maximum fine of $300,000.  
Justice Venning pointed out that Milford Asset negotiated its $1.1 million penalty at a time when Warminger faced significantly more extensive market manipulation charges than were later found proved.  The Financial Markets Authority has first claim on Warminger’s $400,000 fine to meet its costs.       
Financial Markets Authority v. Warminger – High Court (29.06.17)

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