Customer Complaint Dated March 30th 2026

Financial Commission Complaint Response

Complaint Matter

Mr. XXX has lodged this complaint with the Financial Commission on the following grounds:

The Client used account # XXX (USD) for active trading operations in the financial instruments of the energy market (CFDs on crude oil futures). In the period between 26.03.2026 and 27.03.2026 the Client carried out 38 trades in the financial instrument CL-OIL on the specified account. The financial result of this series of trades was a financial loss of 47,888.35 USD. The Client never attached pending Stop Loss/Take Profit orders to their positions in order to limit potential financial losses/secure potential profits on them.

The incident on the Client’s account occurred at market open, on Monday, 30.03.2026, at 01:00 (server time, UTC+3). According to the Client, during the market reopening, they opened two Short positions in the financial instrument CL-OIL with the volume of 5.46 lots and 7 lots, respectively. The Client used Market Sell orders, which were executed by the Broker at 101.08 and 101.78 respectively, with negative slippage. The Client further alleges that at the time:

• The platform displayed price was approximately 102.50,
• The lowest visible price on the platform chart was 101.93,
• The execution prices did not appear anywhere on the chart.

The Client cross-referenced with Bloomberg and five other brokers, proving that the execution prices provided by the Broker did not actually exist in the underlying market at that time, while the Broker blamed the discrepancy on slippage, liquidity constraints, Depth of Market (DOM), and Volume Weighted Average Price (VWAP). It should be noted that shortly after their opening, both disputed positions ## 56927684, 56927725 were closed by the Client at current market prices. The Client made a total profit of 50,474.70 USD from the relevant trades.

The Client does not agree with the Broker’s decision on their complaint (see below) accuses the Broker of misconduct and holds the Broker responsible for the unrealized profits caused by poor execution on the Broker’s platform. The Client is of the opinion that the Broker’s conduct constitutes off-market pricing and a breach of fair execution standards. In this regard, the Client requests that the Dispute Resolution Committee of the Financial Commission verify the execution of the disputed trades, as well as the Broker’s conduct for violations. The Client believes that a fair resolution to the dispute would be a compensation from the Broker for the unrealized profits in the amount of 14,000 USD, which is based on verifiable market pricing. The Client has provided the investigation with the screenshots showing the price dynamics of the financial instrument WTI (May 2026 future contract)/Crude Oil May 26 (CLK26.NYM)/Crude Oil Futures (May 2026) for the period of the incident, taken from the analytical platforms of independent financial services providers (Bloomberg, Yahoo Finance, CME Group), as documentary evidence.

In turn, the Broker does not see any grounds for the Client’s complaint, since in their opinion, all of the Client’s disputed positions was opened and closed correctly, at actual market prices and in full compliance with the provisions of their regulatory documents and trading rules established by the Company. The Broker has provided the investigation with the history of trading/non-trading operations performed on the Client’s account # XXX, the server log records, the Quote Book with the details of the execution of the disputed trades provided by the Broker’s Liquidity Provider, as well as the email communication with the Client regarding the incident, as documentary evidence.

Complaint Response

The decision on this complaint is based on the information provided by the Broker and Mr. XXX.

After a comprehensive analysis of the documentary evidence provided by the Client and the Broker the Dispute Resolution Committee of the Financial Commission has come to the following conclusions:

1. First of all, it should be noted that the incident on the Client’s trading account occurred in the period of thin market (after Rollover), at the very beginning of the Asian trading session after weekend. The Client should be aware that the market very often experiences a significant decrease in liquidity during this period. In turn, this circumstance radically changes the flow of quotes, leading to a sharp widening of spreads and the formation of price gaps. The Client should be aware that trading operations in such market conditions involve significant risks.
2. Second, according to the information received from the Broker:
3. a) At the opening of the Account, the Complainant acknowledged full awareness and acceptance of the Agreement, Notice and Summary.
4. b) On 30.03.2026, the Complainant contacted the Broker’s support team under ticket # 4822757, reporting that the execution prices for their two Sell orders in CL-OIL (5.46 lots and 7 lots) at 101.08 and 101.78 did not match the chart prices shown on the platform (which indicated prices around 102.5 with a low of 101.93).
5. c) Based on the internal investigation, the relevant team found that the disputed orders ## 56927684, 56927725 were executed correctly at the prevailing market prices according to available liquidity.
6. Third, the Broker clarifies that their further investigation of the server logs, tick-by-tick data, and trading records confirmed that the executions occurred at prices consistent with the available Bid/Ask quotes in the market depth at the precise time of orders submission around 01:00 on 30 March 2026. According to the Broker, there is no evidence of any pricing error, execution failure, or system malfunction. The difference between the chart price (which typically reflects last traded or aggregated data) and the actual fill price for large volume is attributable to normal liquidity-based execution mechanics under the prevailing market conditions.

The Broker emphasizes that even in the ordinary course of market operation, slippage between the offered price and the actual price at which the Market order is executed could very well occur and such slippage could be exacerbated by:

Market Volatility: Trades may experience slippage during periods of high volatility, especially when strong market trends are present. Market volatility can be caused by technical or fundamental factors in the market or the release of news or information. Liquidity Issues: When large orders are triggered, execution fills at the next available price(s) in the Depth of Market, which can be affected by market volatility and liquidity. Trading Volumes: Significant volume can impact execution due to depth of market or the lack thereof.

In this regard, in support of its position, the Broker refers to the relevant provisions of their regulatory documents:

Risk Disclosure Notice ▪ Clause 8: Liquidity risks arise from the lack of ease with which securities can be bought or sold i.e. situations in which an investor desirous of trading a security cannot do so because of lack of or deficient demand in taking the other side of the bet. ▪ Clause 9: During periods of heightened market volatility, spreads can be wider than usual and will cause the cost of closing positions to be greater and gapping can arise. The effect of gapping is that stop-loss orders are executed at an unfavorable price.

Client Agreement ▪ Clause 1.1: Investors are required to carefully read, understand, and accept the Agreement. By signing and submitting the Application Form to set up the Account, the Complainant acknowledged full awareness and acceptance of the terms (including the Agreement and all incidental documents) governing the account. ▪ Clause 1.4(c)(iii): the Broker provides execution-only services and any decision or trade made by the Complainant are made entirely at his own election and risk.

Key Facts Summary ▪ Clause 5.8: This clause confirms that quotes for dealing are indicative only and are subject to the actual price at the time of execution of the investor’s order. the Broker gives no assurance nor assume any responsibility that the order will be executed at the price of the Complainant’s order. As such, the Complainant bears the financial consequences of the normal market operations and slippage in times of heightened volatility or extreme price movements.

4. Fourth, to ensure an objective investigation of the case the DRC requested historical data on the financial instrument in the disputed transactions from other independent providers of financial services. The Financial Commission uses several different sources, such as Tradeproofer, Tradefora, Verify My Trade, TrueFX, FX Benchmark and some others for the purpose of verification of the quality of trades’ execution. The analysis of the quote flow of other companies reveled that:
5. a) At the time the Short position # 56927684 was opened, with a volume of 5.46 lots (5,460 barrels), the market average Bid price for the financial instrument CL-OIL was 102.56, i.e. it was significantly higher than the Broker’s execution price of 101.781.
6. b) At the time the Short position # 56927725 was opened, with a volume of 7.00 lots (7,000 barrels), the market average Bid price for the financial instrument CL-OIL was 102.007, i.e. it was significantly higher than the Broker’s execution price of 101.083.

As such, it is obvious that the quotes for the financial instrument CL-OIL in the Broker’s quotation feed differed significantly from the quotes obtained from other independent financial service providers and, consequently, did not reflect the actual market conditions.

5. Fifth, the Client states that the slippage during the execution of the disputed trades was excessive and did not reflect normal market conditions. For its part, the Broker states that they have confirmed with the Liquidity Provider that no pricing or execution errors occurred at the time of execution of the disputed trades. Furthermore, the Broker notes that the Client’s orders were executed by aggregating liquidity across several price levels in the Depth of Market (DOM). This resulted in execution at the volume-weighted average price (VWAP) indicated in the trading history for the Client’s account. The experts of the DRC considered the Broker’s position to be correct, since large market orders are always executed using the “volume-weighted average price” (VWAP) method: if the required number of lots is not available at the best price (Top of the Book), the system takes what is available and moves on to the next, less favorable price level until the entire volume is filled. This inevitably leads to slippage. In this regard, it should be noted that judging by the documentary evidence received from the Broker’s LP (the Quote Book volumes at the time of the trades in question), the following was confirmed:
6. a) The order # 56927684 was executed via the LP in several parts. The order was for 5,460 barrels, and the Quote Book at the time of execution resulted in an average price for the whole order of 101.781 at open, while the requested top of book quote was 102.494.
7. b) The order # 56927725 was executed via the LP in several parts. The order was for 7,000 barrels, and the Quote Book at the time of execution resulted in an average price for the whole order of 101,083 at open, while the requested top of book quote was 102.344.

The analysis of price levels and volumes in the Depth of Market (DOM) for the relevant period, as received from the Broker’s LP, has not identified any significant deviations in the Broker’s prices. The order book logs confirmed a lack of liquidity at the best bid for the required number of lots. Therefore, to fill the Client’s required volume, it was necessary to gather liquidity across several price levels. In other words, the VWAP mechanism functioned correctly.

6. Finally, with regard to slippage during execution of market orders the following should be noted. The Client should be aware that a Market order is a command to Buy or Sell an asset immediately at the best available current price, prioritizing speed over price precision, ideal for fast entry/exit but risky in volatile markets due to potential slippage. A Market order does not inherently guarantee that the client’s instructions will be executed at the indicated price. Depending on the market situation such order may be executed either precisely at the price indicated by the platform, or at a price better/worse than the indicated one. The client should use Limit Buy /Limit Sell orders to get an execution at a guaranteed price. Furthermore, the Client should be aware that slippage arises from natural market dynamics, particularly in low-liquidity periods. Also, for trades involving larger lot sizes, available liquidity at the requested price level may not fully accommodate the order volume. Consequently, portions of the trade execute at successive price levels, resulting in apparent negative slippage. This phenomenon is standard in low-liquidity, low-volume markets and reflects normal liquidity behavior rather than execution inefficiency.

Summarizing all the above the Dispute Resolution Committee has ruled in favor of the Broker. Taking into account abnormal market conditions in the period of the incident, the experts of the DRC found that the Client does not have sufficient grounds to assert that the disputed transactions ## 56927684, 56927725 carried out on trading account # XXX were executed by the Broker incorrectly. The slippage experienced by the Client was due to market illiquidity during the period in question. Such risks were clearly disclosed in the Client Agreement and Risk Disclosure, which the Client acknowledged and accepted upon account opening. Accordingly, the Client’s claim for compensation for unrealized profits in the amount of 14,000 USD caused by excessive negative slippage during execution of their Market order was deemed unfounded by the DRC.

This complaint was reviewed by the members of the Dispute Resolution Committee of the Financial Commission and was processed by the Head of the Committee.

If you have any questions regarding this investigation, please send them to the following address: info@financialcommission.org

Acknowledgement

I certify that all information was considered by the Dispute Resolution Committee of the Financial Commission and hereby confirm that the decision was made fairly, impartially and without interference. I am confident that the information provided in the document is true.

Awards and Orders

• DRC decisions are binding on Brokers. DRC decisions are binding on clients only if they accept them.
• If complainant agrees with DRC’s decision, he’ll need to accept it within 14 days. If the Client does not respond to the DRC’s decision within 14 days the complaint is considered closed.
• Member must award the settlement within 28 days of when the decision was reached.
• If the decision was in favor of the Member, the Client must provide a release for the Member within 7 days of when the decision was made and the complaint is considered closed.
• The Compensation Fund will be only used should a Member refuse to adhere to a judgment from the Financial Commission or if a Member is removed from the Financial Commission without paying their outstanding judgments.
• The Compensation Fund will only cover judgments up to €20,000 per client.