FinanceFeeds detailed review of 2017. January to March – Prime of prime liquidity, the demise of a giant, and your customer database

As 2017 draws to a close, we look at the important details that shaped the industry this year, beginning with January to March as the first part in a four part series this week. FinanceFeeds remains committed to detailed reporting from within the industry’s major centers and continuing to work closely with the most important companies that shape the entire future of this business internationally.

2017 has been another very eventful year, however there have been some distinct differences between the past twelve months and the developments that have formed the commercial landscape for the majority of this decade.

In particular, the entire spectrum of the FX industry does not resemble its structure at the end of the last decade, when MetaTrader 4 was in its relative infancy and a plethora of small brokerages made their way onto the retail market, as nowadays, a combination of consumer wisdom, regulatory understanding in some of the more important regions, and a need to elevate the standard of smaller brokerages with third party solutions away from the ‘second tier’ status that they have held until now in the shadow of the large, publicly listed companies in the world’s most technologically advanced major financial centers.

FinanceFeeds has committed vast resources to reporting and conducting research from within the companies that lead this industry worldwide, a matter which we consider as vital as working with our esteemed and high level partners whose expertise and engagement assist us in providing the absolute detail on every aspect of developments in this business globally.

In this four-part series this week, FinanceFeeds takes a detailed look back at the events of the year that have been influential and changed the direction of our industry, in chronological order:

January 2017

At the beginning of the year, FinanceFeeds considered the M&A deals that have amounted to hundreds of millions as massive venues mop up institutional FX firms – not retail client bases for a few million.

It was anticipated by many senior FX industry figures that a large scale consolidation would occur in 2017, at a much higher level in the ecosystem and for very high values.

Partly, this notion was driven by the notion that institutional providers that specialize only in FX and CFDs are now under the scrutiny of banks, and have also become a target for Britain’s FCA which begin reviewing a set of new rules that have been proposed to severely restrict the method by which CFDs are provided, and CFDs are a core business for many brokers in Britain.

In January last year, it was considered that this will create a two way difficulty. The first is that maintaining Tier 1 bank relationships is currently increasingly capital-hungry, therefore $50 to $100 million must be tied up in that alone.

The second is that if the reduced leverage and restrictions take place, it will provide much less margin for OTC firms offering CFDs, yet they will still have to please the banks by lodging a fortune in capital. Whilst at the time this was viewed as the potential cause of a squeeze, later on in 2017, banks began to realize that they cannot survive without the vital OTC FX order flow that serves the retail market, and began to open up liquidity channels once again, albeit with very strict due diligence.

Prime of prime relationships and the lack of counterparty credit extension by banks was very much a moot point in January this year.

Andrew Ralich, CEO of integration, liquidity management and MetaTrader bridge development company oneZero Financial Systems explained to FinanceFeeds “From a technology perspective, the SNB event was a catalyst to a massive change in brokers demands for creative solutions for credit, clearing and execution. As Tier 1 Prime Brokerages have tightened restrictions on both blanket credit worthiness and amount of credit provided, a void has grown in the PB and Prime of Prime space.”

“That void has been slowly filled by new non-bank participants. Two types of firms have lead the charge, first is those who have direct bank relationships as the result of strong balance sheets or through participation in other asset classes (for example, future brokers or hedge funds who previously did not utilize their available NOP and have reallocated some of their credit to FX B2B). Secondly, larger Retail brokers have also stepped, leveraging their existing liquidity relationships and credit facilities to evolve into B2B providers” continued Mr Ralich.

“In both cases, new technology solutions which facilitate B2B clearing for multi-asset, or maturing Retail brokers have been in high demand. We have seen considerable take up in or Margin Engine, pre trade risk management and back office functionality from participants who previously did not engage in the B2B space” said Mr. Ralich.

“In parallel, constricting margins across the board, due to the increased cost of clearing, are also forcing brokers to look into consolidating technology costs. This has been another key driver for business growth for firms like oneZero who offer hybrid retail/institutional platforms at a consolidated price point. It’s amazing to see this far from the event, but the dust has still not completely settled. I expect a further evolution in alternative clearing solutions, coupled with non-bank pricing to occur over the next 3-5 years as banks continue to distance themselves from the retail vertical in both clearing and liquidity provisioning” – Andrew Ralich, CEO, oneZero Financial Systems

Richard Elston, Head of Institutional at CMC Markets spoke to FinanceFeeds in January, explaining “The Prime Broker model is a shadow of its former self – the number of banks playing in this space has contracted significantly and they have quite simply become a lot more selective over who they are willing to do business with. Internal risk management is the big driver here, although being a listed company with a multi-million dollar market capitalization and a strong, publicly reported balance sheet, certainly helped build our relationship with a range of providers over what has been a turbulent period.”

Keeping customer accounts safe was also a subject for conversation in January.

Cybersecurity, the terminology given to the protection of information systems from theft or damage to the hardware, the software, and to the information on them, as well as from disruption or misdirection of the services they provide, is paramount and therefore access to the right information from all parties is a given…. or is it?

In early 2016, research by McAfee Labs, the internet security and anti-virus research division of Intel Security, has this week concluded that only 42% of cybersecurity professionals use shared threat intelligence, despite 97% of those who do use it having stated that it helps them provide a better counter-threat service and with 59% having stated that shared data is “very valuable” to their organization.

The FX industry is so multi-faceted that the need for cybersecurity exists in many specific areas such as the electric payment processing sector, the safeguarding of client funds in online trading accounts and the actual access to trading accounts themselves in order that trades can be opened and closed.

FinanceFeeds noted that is advisable when inserting affiliate links into websites that they are as originally defined, and that they do not appear to show unusual or differing characters than when they were inserted. These could be used to deploy ransomware, thus the advertisement which looks quite correct when viewed on a broker website may be contaminated with malware and once it is there, it is very very difficult to remove.

Brokerages, IBs and their clients should be very wary of emails which prompt them to update their passwords. For clients, these could be trading account access passwords, for IBs they could be portal or CRM passwords and for brokers they could be back office passwords.

Anything that appears to be automatically generated and does not come from what appears to be the correct format of internal corporate email address, our advice is not to click on it as it could contain code that grants hackers access to the trading account of retail clients, or the database owned by a broker, or even worse, the withdrawals system.

We are aware of insidious second-rate brokerage software providers (who are also market makers despite their reluctance to admit it), whose system has been innately designed so that it gives away the entire customer database of its affiliates. Avoid at all costs.

Leverage and concentration on trading terms by regulators was a poignant matter in January.

In early December 2016, the United Kingdom’s Financial Conduct Authority (FCA) proposed leverage caps for retail CFD Brokers which will be dependent on the experience of the client. The proposal can be found in the FCA’s Consultation Paper CP16/40 entitled Enhanced Conduct of Business Rules for firms providing contracts for difference products to retail clients, which is open until March 2017. However most CFD brokers in the UK are anticipating that shortly afterwards, it will come into effect.

Following on from the FCA’s announcement, retail CFD brokers felt the effects of the proposed changes almost immediately. Some of the biggest players in the retail CFD industry found their share value dropped by at least 20%.

By January this year, the question that the industry wants answered was, does the Australian Securities and Investments Commission (ASIC) have the power to implement the same leverage restrictions?

As ASIC draws on a variety of sources for its power, there are various mechanisms ASIC could use to restrict retail margin FX and CFD brokers in their dealings with clients, and there’s some that they cannot

February 2017

February this year was a month in which the retail FX industry changed forever. One of the longest established and largest FX companies fell foul of an outright ban by the National Futures Association (NFA) in the United States.

That particular company was FXCM.

The NFA alleged at the time, and still continues to maintain that from September 4, 2009 until at least 2014, FXCM and FXCM Holdings, by and through their officers, employees, and agents, including senior executives Drew Niv and William Ahdout, engaged in false and misleading solicitations of FXCM’ s retail foreign exchange customers.

The NFA’s case decimated the company, and alleged that FXCM represented to its retail customers that when they traded forex on FXCM’s “No Dealing Desk” platform, FXCM would have no conflict of interest. According to these representations, retail customers’ profits or losses would be irrelevant to FXCM’s bottom line, because FXCM’s role in the customers’ trades was merely as a credit intermediary. According to FXCM, the risk would be borne by banks and other independent “market makers” that provided liquidity to the platform.

In contrast to this, the NFA maintains that FXCM used a separate market maker, in this case EFFEX Capital, to trade against FXCM clients, whilst FXCM had an undisclosed interest in EFFEX Capital and was profiting from rebates gained from trading activity.

The case continues, and none of this has been proven, however FXCM’s standing in several regions has reduced, and the firm which was founded subsequent to FXCM’s ban from the US, Global Brokerage Inc, filed for bankruptcy very recently.

FinanceFeeds has been absolutely tenuous in reporting from the actual legal proceedings as the year has progressed, providing vital and exclusive information from the actual legal documentation.

ASIC licence? Are you sure?

Whilst the vast majority of the burgeoning FX industry within China is highly organized and operated by astute professionals with vast, in depth industry knowledge who are able via joint venture partnerships to propel the revenues of Western brokerages to stratospheric levels with very little effort or difficulties, there are still one or two flies in the ointment.

China’s ringfenced business environment which keeps it completely isolated from the rest of the world and at the same time totally domestic focused with its own isolated domestic market only internet, government intervention in all aspects of commercial life, internet censorship from the outside and almost complete lack of even single syllables of the English language, the dichotomy that exists is that everyone needs China rather than vice versa, yet from the outside, clarity and navigating any form of data is virtually impossible.

The amateurish counterfeit MetaTrader 4 platforms that proliferated the second tier development towns across provincial China are thankfully becoming a thing of the past as modernity and sophisticated corporate structure is paramount among large IBs that have in many cases more capital resources and are responsible for more client assets than many actual brokerages outside China, however during the past few weeks a new pitfall has emerged that brokerages should be aware of.

Several sources from within mainland China explained to FinanceFeeds in February that some brokerages are being targeted by local Chinese agents that make the false claim that they are able to sell Australian Securities and Investment Commission (ASIC) licenses to brokerages, and that they are the authorized Chinese official for such a transaction.

This is completely bogus because there is only one method by which to obtain an ASIC license and that is by direct application to the Australian authorities, and with clear evidence that the company applying has operations in Australia and the correct responsible directors in place, on Australian territory.

Even with such a structure that complies with the criteria, ASIC has over the past two years begun to show reluctance to grant ASIC licenses to margin FX firms with retail client bases as part of its ultra-conservative view on OTC retail margin FX in Australia.

FinanceFeeds at the time had been aware of several instances of this practice prevailing in mainland China, and in some cases the impostors actually explain to the brokers that they wish to sell such counterfeit licenses to that once purchased, the brokerage would be authorised to handle client funds and conduct FX brokerage services as per the terms and conditions of a genuine ASIC license.

The reality is that rather than being an actual ASIC license, what the brokerage receives instead is a Special Administrative Region (SAR) license which has very little value whatsoever.

The difficulty is that due to the almost complete lack of use of any aspect of the English language in China, many brokerages or Chinese divisions of Western brokerages believe the agent and actually buy the license, unaware that it is not real, with the agent taking between $10,000 to $20,000 as a one off fee.

Be very careful to avoid this practice because in this case, STP really does mean Straight To Pocket.

Also in China, FinanceFeeds CEO Andrew Saks-McLeod addressed 300 senior FX industry executives in the mainland, regarding how to approach the all important Chinese IB and brokerage sector during 2017.

“We are speaking today about the new ways that media in China will have to be used in order to attract and maintain a sustainable client base as well as organically grow any business, and from my research, the only method now is to concentrate on media campaigns that are based in China, originate from Chinese entities – meaning Chinese hosted and partially owned subsidiaries of Western brokerages or technology firms, and not to make any media campaigns that focus on China, from outside China” – Andrew Saks-McLeod, CEO, FinanceFeeds

The reason for this is that nowadays, with large introducing brokers in regional towns and cities that are highly astute and operate offices with in some cases over 100 staff and perform every possible activity that a retail brokerage itself would perform including portfolio management via MAM accounts with in house money managers, full payment and withdrawal services, back office and customer relations departments and a customer-facing sales team, the Chinese retail trader is today more empowered than ever, yet totally focused on the relationships with large IBs” said Andrew Saks-McLeod to the audience, which consisted of over 250 executives from mainland China, all representing Chinese and international FX companies.

There is no point at all in purchasing football sponsorship, or buying media remotely from outside China, as not only has this been severely restricted by Baidu’s advertising clampdown on OTC derivatives firms from abroad, but the high costs and difficulties in knowing where to position such media will be further thwarted by the inability for the increasingly small number of clients that would click on such an advertisemnt rather than deal directly with their existing firm to send their funds overseas.

These companies are hosted locally and have become vast household names across mainland China, and are free to be able to use local and national Chinese media channels to attract and maintain a relevent audience without restriction on conversion via advertising or transfer of capital to trading account, thus, in today’s world, the only means of using the media correctly is to do as companies that have already taken the steps of founding joint ventures or have opened Chinese offices.

Joining FinanceFeeds in a discussion panel was a senior executive from Chinese cross-platform mobile messaging firm WeChat, which is very similar to WhatsApp in its functionality, however is for the domestic Chinese audience.

WeChat has become a vital tool in use among all introducing brokers. FinanceFeeds has met with introducing brokers across the country which have portfolios of over $250 million onder management, all of whom use WeChat as the main source of media as well as connection with their customers. That particular discussion highlighted that introducing brokers are reliant on developing massive WeChat networks, regardless of size or amount of assets under management.

March 2017

London’s Tier 1 banking powerhouses may well represent 49% of all global electronic order flow, however most certainly, the prime of prime brokerages which maintain liquidity relationships with the world’s most recognized banks and share the same Square Mile are also looking beyond the interbank heartlands of London and into the all important Asia Pacific region.

Established prime of prime brokerages in London have in many cases gone to the Far East by establishing Chinese and Hong Kong based divisions, however for the recently established elite, this is also a priority.

In March this year, at the industry’s heartlands in London, FinanceFeeds spoke to Wei Xu, Operations Manager at Stater Global Markets, which was established last year by astute and urbane former Citigroup executive Ramy Soliman, whose career path exudes knowledge on the interbank and retail side of the business, his five year Citigroup tenure preceded by five years at IG Group’s institutional division.

Wei Xu joined Stater Global Markets in August 2016 from Integral Development Corporation where he was Technical Account Manager, having spent one year in the position following three years at Gold-i where he was promoted half way through his tenure from Technical Support Engineer to Head of Support.

Leverage, spreads and commission at that time were still the main priorities for local retail brokers and liquidity takers according to Mr Xu, however they are also seeking a creditable counterparty. It’s important to them that they are dealing with a reputable and creditable UK entity, a facet that Mr Xu concurred with, and MT4 is still the heavily preferred platform in Asia, particularly in China, due to its ease of use.

However, there are a few brokers who are starting to look at more institutional platforms in order to differentiate themselves from other brokers. Being able to offer both retail and institutional platforms actually gives us an advantage when talking to potential clients. They welcome the choice.

With regard to how the entire ecosystem from liquidity provision to prime brokerage right down to the retail client front end will be hosted in China, and connected to global liquidity via Chinese branches of Western PBs with their entire infrastructure hosted and situated in China could create a massive surge forward in Chinese business as it will be within the government’s remit of being supervised from the inside has been a subject of much ambiguity this year.

During our conversation in March, Mr Xu explained that it is very difficult to predict how the market and the ecosystem that supports it will develop to service China. Seeing how Asian hubs like Singapore and Hong Kong develop will provide a good indication of the direction. As regulatory developments happen, this will be the driver for the ecosystem that will be built.

“I think the contraction in the credit appetite at the large Prime Brokers justified the business need for Prime of Prime to be established. At Stater, our objective was to offer as much of the Prime Broker service to an audience that found it harder to access (PB derived liquidity and credit intermediation)” said Mr Xu.

Insidious advertising to a VERY loyal audience

There is an unwritten and relatively widely understood practice which has dogged the genuine and reputable electronic trading industry for quite some time now, that being that the established large retail FX firms of London, New York and Sydney as well as their institutional compatriots that provide aggregated Tier 1 liquidity via equally well established liquidity management firms quite simply do not need to engage in vast and expensive mass market offline advertising campaigns, nor do they need to buy the media so that they say nice things about them, as their pedigree is well earned and stands itself out.

On the other hand, nefarious binary options companies, which do not belong in the same category as any entity in the electronic trading industry, their roots being in lead buying (or stealing), affiliate marketing, gambling or other forms of vice, and whose leaders have educational and career backgrounds that represent a complete dichotomy when compared to those who lead the genuine electronic trading firms, having gained their knowledge via internships at major institutions before becoming skilled professionals within either eFX divisions of large banks or institutional liquidity providers before becoming senior executives of publicly listed firms on reputable stock exchanges, are polar opposites.

Ordinarily, the lowbrow binary options business would have from its very origin have been castigated by most due to its absolutely fraudulent nature, which has now attracted the attention of regulators globally, as well as national governments, many of which have banned it completely from being peddled on their shores, and rightly so.

In March this year, FinanceFeeds examined a problem that has arisen in that these companies have so little substance that they need to buy the media as well as buy the confidence of an unsuspecting retail audience, hence massive marketing budgets compared to the smaller marketing budgets of established and proper firms, in order that the media says nice things about them and aligns them with the bona fide firms, and vast offline campaigns that involve in many cases associating themselves with brands that have extremely loyal fans, such as Premier League football teams.

Back in September 2016, FinanceFeeds succeeded in lobbying British football team Southampton FC in an attempt to ensure that it canceled its sponsorship deal with Banc de Binary, in which it was pointed out that associating such a firm with a highly trusted football team would be disastrous for the followers of Southampton FC.

Unfortunately, however, the practice continued to manifest itself, this time with West Bromwich Albion, a British football team based in the Midlands, having signed a sponsorship deal with IGOFX, which clearly demonstrates that yet again, very little due diligence was conducted by the sports sponsorship agency that brokered the deal between IGOFX and West Bromwich Albion.

Where do we start?

First of all, IGOFX, despite its misleading name, is not an FX company at all but actually a binary options brand that simply operates a sales floor and takes its full solution from a binary options market maker.

The firm is registered in Vanuatu, which is a region which has become relatively popular recently with companies attempting to circumvent regulation, or which do not want to have to adhere to right and proper regulatory stipulations in recognized electronic trading jurisdictions.

Rather than falling into the category of electronic trading, IGOFX is more of a multi-level marketing (MLM) scheme, with many sites in that sector making reference to it.

The domain, was registered on August 13, 2012, and there is absolutely no record of the firm’s physical location. Quality companies that are supposed to be custodians of customer funds and provide genuine financial products to a retail audience that do not provide their full commercial details are as rare as rocking horse dung. It is as simple as that.

The IGOFX Compensation Plan

in March, we looked into how this works. According to many sources in the multi level marketing sector, IGOFX affiliates invest $100 or more on the promise of a passive monthly ROI of between 10% and 30%.  IGOFX affiliates earn a 5% referral commission on funds invested by personally recruited affiliates.

Residual Commissions

IGOFX take 10% of monthly ROI payments to affiliates and use them to pay residual commissions. These residual commissions are paid out via a unilevel compensation structure. A unilevel compensation structure places an affiliate at the top of a unilevel team, with every personally recruited affiliate placed directly under them (level 1).

If any level 1 affiliates recruit new affiliates, they are placed on level 2 of the original affiliate’s unilevel team.

If any level 2 affiliates recruit new affiliates, they are placed on level 3 and so on and so forth down a theoretical infinite number of levels.

IGOFX cap payable unilevel levels at four, with commissions paid out as a percentage of monthly ROIs earned by unilevel team affiliates:

level 1 (personally recruited affiliates) – 5%
level 2 – 3%
levels 3 and 4 – 1%

Note that residual commissions are not paid out to IGOFX affiliates who have not recruited at least three affiliates who have invested.

MT4 Trades

In addition to passive ROI payments, IGOFX affiliates can also “mirror” trades fed to them by the company. This is achieved through third-party MT4 trading software, with performance varying from month to month.

This is an absolute danger to our industry, and the most difficult aspect here is that because there is no regulator overseeing the conduct of this firm, there is no means of censuring it or monitoring its conduct, thus not much can be done unless it becomes a police matter, which is highly unlikely unless there is genuine discourse from customers that can prove any wrongdoing, which is nigh on impossible.

Therefore, companies such as this continue to advertise on mainstream, widely trusted strips such as West Bromwich Albion, whose fans, rather like those of Southampton FC, and Juventus which has still got 24Option sponsorship prominently placed on its shirts, and as FinanceFeeds pointed out during the past few days, has been able to display such advertisements on French websites despite the ban on binary options adverts.

Whereas 24option and French football club Olympique Lyonnais have terminated their partnership amid a wider wave of such partnerships brought to an end in France, the deal with Juventus FC is on and is freely promoted across the web, a prominent example being 24option’s French website displaying a banner of the partnership between the binary options brand and Juventus FC.

It is exactly this type of high profile advertising of binary options firms that has led to the banning of OTC derivatives advertising in many nations and is potentially damaging to the entire right and proper industry, the damage being created by pretenders rather than genuine participants, hence it is toxic to the core and should be of great concern to our valuable industry.

On June 29 last, 24Option extended its sponsorship of Juventus for another year. This shows the absolute rise to wealth of these marketing-led brands.

FinanceFeeds reached a few organizations in London that spend significant time in masterminding sponsorship bargains for football groups, all of which clarified that it would be consummately adequate for them to acknowledge such companies as supporters, until we clarified the genuine size and potential results of advancing such firms and their exercises toward the reliable aficionados of football groups.

London’s West End is a major center for PR agencies and media entities that specialize in putting together branding and sponsorship deals. We ask where the due diligence is, and of course it does not exist.

Great Portland Street has for many years been home to a plethora of specialist agencies, some very large, that work with blue chip firms and broker branding an sponsorship deals with large sports teams as well as other high profile visuals such as television and entertainment.

To find out whether such firms consider sport sponsorship by binary options brands ethical, FinanceFeeds approached Synergy, which nestles deep in the heart of London’s trendy media heartlands in Great Portland Street. When asked whether they would take a binary options brand and broker a deal with a football club, and whether they consider this unethical, the representative explained “No, we work with any firm that looks to improve their branding.”

“We work exclusively brand side” she continued to explain. “One of our services is consultancy, in which we have a look at the portfolio of the brand, and then we look at the sponsors that may suit. We work for big blue chip clients often on this basis.”

“We don’t think it is unethical to broker deals between football teams and binary brands” she said. “If it is right for the brand or rights holder, then we go ahead. We look at he brand, value, ROI, it’s not an easy yes or no.”

We believe that the agencies see the dollar signs and do the deal, not realizing the true business models that these firms employ, therefore some degree of providing information to marketing and PR agencies is also needed in order to stem this level of high profile sponsorship.

An additional caveat to bear in mind is that football shirts, and what is written on them, are massively influential to children and teenagers in parts of the world in which football is a very popular and almost religiously followed sport. Football clubs often sell merchandise versions of the shirts of the stars that children and teenagers who love football admire, therefore by having binary options names on football shirts, minors by default could be inadvertently standing themselves up as ‘ambassadors’ to this fraud, or even worse getting taken in by it themselves.

The internet is awash with a litany of appalling experiences from customers and former staff of such firms, thus it would be very easy for a sports sponsorship agency to conduct some degree of due diligence, even if they are unfamiliar with the online trading industry.

Football clubs are followed religiously by their loyal and devoted fans, and thus not only would any advertiser be trusted by its fans, hence they may be tempted to deposit funds to such a firm, meaning that by proxy, the beloved football club of thousands of fans would be an accessory to them losing their money to a binary options scam, as well as them being ambassadors to it by wearing the club’s merchandise.

This extremely powerful marketing trick alludes to the gaming and affiliate marketing background that most of these firms have their roots in. In some cases, they do a deal in which the customer database becomes available to both parties, which is very much a cause for concern.

Fortunately, binary options has been outlawed by many regions, however the bandits that perpetrate it are now morphing into other schemes, one of which was barely heard of in March this year, but now dominates the entire sub-standard, pseudo-financial internet space, that being the ICO.

It is very interesting how nefarious schemes on the level of binary options can disappear along with billions of dollars of money belonging to customers who were duped into believing that they were making an investment rather than simply having their money stolen by boiler room sales staff whose employers simply pocketed it and never traded it on any market can change into a different scheme, this time offering venture capital-type investments in startups, using a false currency to invest in a token that does not exist.

FinanceFeeds will cover that in the next part of the review of 2017, along with the massive steps forward made by the genuine FX and electronic trading entities that we can thank tremendously for upholding the good quality technological, commercial and progressive standards.





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