May 13th 2021, The Financial Commission today announces steady month over month figures for newly filed complaints, resolved complaints and other key metrics for April 2021 as part of its monthly Complaints Digest. The organization also experienced a continued rise in trading related complaints while average dispute resolution times fell to just 5.6 days for the month.

Key monthly highlights for April 2021:

Month Over Month Comparison

Key Takeaways

Conclusions

Trading in global markets with a new focus on digital assets and derivatives has continued to support demand for external dispute resolution services (EDR), as highlighted by several key metrics of the Financial Commission for the last month. Increases in trading related complaints by 29% suggest more traders are taking advantage of market opportunities and having issues with trade execution or pricing. Roughly 26% of all new complaints filed with the Dispute Resolution Committee (DRC) in April were valued at $1,000-$10K, highlighting the continued importance of the organization to investigate complaints with a significant monetary value. During the month, the DRC was able to speed up the resolution of cases with average resolution times falling by 32% to just 5.6 days. 

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].

April 21st, 2021, The Financial Commission today announces the publication of new case examples highlighting the dispute resolution process of the organization and common themes among disputes processed in the last 6 months.

To review the newly published cases, please click here.

The examples published today provide a detailed analysis of customer’s orders based on market conditions and pricing information from a variety of independent sources in order to determine the accuracy in pricing and quality in the execution of Contracts for Difference (CFD) orders on customer accounts. 

Such resolution efforts led to compensation of over $18,000 in two of the highlighted case examples published today and over $1,205,000 awarded to “trading related” complainants in total for the 2020 fiscal year.

The Dispute Resolution Committee continues to pay particular attention to trading-related cases and in light of the fact that traders around the world are looking to check both the prices they receive for FX and CFDs, as well as the speed and accuracy of their trade executions. The Committee also notes the rapid expansion of trading products, including CFDs on equities, digital currencies and indices, which are becoming increasingly popular among retail traders. 

The Financial Commission regularly publishes case examples for the trading community and brokers to review in order to understand the issues that often arise as a result of trading and the ways in which the organization resolved such issues between brokers and their customers. The publicly available information is valuable in both educating traders, as well as improving the services and products offered by brokers.

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected]

Complaint Matter

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

The Client used account # XXX (USD) for active operations with cryptocurrencies.

The Client used account # 8809629 (USD) for active operations with Forex market instruments and CFDs. According to the Client, the specified account was registered on October 13, 2020, and funded with 7990.43 USD on December 21, 2020. On the same day, the Broker credited bonus funds in the amount of 1598 USD to the Client’s account. 

By the day of the incident, the Client established 21 Short positions with the financial instrument USOIL with a total volume of 538 lots. The incident on the Client’s account occurred on January 4, 2021, at 12:31:34 (server time). At the specified time the Broker deducted all overnight fees obtained from USOIL positions established by the Client. As a result, this circumstance led to debit of bonus funds from the Client’s account, as well as forced liquidation of the Client’s positions ## 56617870, 56617871, 56617872, 56618848, 56618862, 56623804, 56623805, 56623832, 56623833, 56623834, 56691961 due to deficit of margin (Stop Out). The number of the Client’s losses incurred by the incident totalled 6135.30 USD. Also, it should be noted that shortly after the incident the Client covered the rest of his positions in USOIL manually, at market prices, with additional losses in the amount of 1006 USD. 

The Client does not agree with the Broker’s decision (see below), accuses the Broker of misconduct and requests the Dispute Resolution Committee to check the legitimacy of the Broker’s actions in the period and after the incident. The Client believes that a fair resolution to the dispute should be compensation of financial losses incurred by the incident (7000 USD) from the Broker. The Client provided the investigation with the screenshot taken from the Broker’s platform, as well as the screenshot taken from the live chat, as documentary evidence.

In turn, the Broker does not see any grounds for the Client’s complaint, since in their opinion all Client’s positions were closed correctly, at actual market prices and in accordance with the provisions of the regulatory documents and trading rules established by the Company. The Broker provided the investigation with the trading history of the Client, the server log records, the Bonus Promotion T&C, as well as the official response to the Client on this claim, as documentary evidence. 

Complainant Broker
XXX YYY
Financial Commission Complaint #ZZZ
Complaint Raising Date Complaint Filing Date
17/01/2020 28/01/2021
Complaint response:

The decision on this complaint is based on the information provided by the brokerage company and the Client.

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. According to the information received from the Broker, they have experienced a Swap incident on USOIL positions that were incorrectly charged to their clients starting December 23, 2020. The Broker sent out client communication on January 4, 2021 prior to the actual adjustments to inform affected clients that investigation is in place and adjustments would be made shortly. On the same day, adjustments were made and client communication sent to inform affected clients. In this regard the Broker claims that they acted in full compliance with the provisions of the regulatory documents and refers to the appropriate clauses of their Client Agreement:

2.5 CHARGES AND CREDIT TO YOUR ACCOUNT

(c) If we discover that we have made an error in respect of any fee calculation, we will rectify that error

by giving you written notice within 28 days. 

3.5 ERRORS IN PRICES

Errors in pricing may occur from time to time. In these circumstances, we may adjust any element of your Position. See section 3.7 of the Product Disclosure Statement for more information about the basis on which we can do this. 

12.1 EXCLUSION OF LIABILITY

To the maximum extent permitted by law, we are not liable for: 

  1. f) any Error that may occur; 
  2. h) any error or inaccuracy in, or unsuitability of, or omission from the Agreement, or any other information provided by us, whether negligent or otherwise; 
  3. i) any Loss or Claim suffered or incurred by you in respect of our Trading Platform including due to the unavailability of the Trading Platform or Trading Platform, system and data errors, delays, inaccuracies, errors or omissions in data provided to you, software or computer viruses or the unauthorized use of the Trading Platform at any time;

2. Also, the Broker claims that the Client received their Credit Bonus under the condition that the Client’s account equity balance must not fall below credit balance, otherwise, the Credit Bonus will be removed, as outlined by the provisions of clause 16 of the Bonus Promotion Terms & Conditions:

  1. If your Account Equity balance falls below the credit balance the trading credit will be removed and your open trades will be closed. 

The Broker claims that the Swap adjustment made to the Client’s account lowered his account equity level and triggered the removal of the Credit Bonus. It was also partially due to an overnight USOIL price increase from 48.351 to 48.941, which enlarged the Client’s trading loss.

3. It should be noted that trading terms for the Client’s account suggest a floating spread and a Stop Out at 20% level. This information is clearly defined by the Broker’s regulatory documents (see Product Schedule). By opening a trading account of the selected type, the Client agreed to accept the trading terms provided by the Company. According to the Broker, at the time of the incident, the Equity/Margin ratio on the Client’s account fell below the critical 20% level. As such, due to insufficient margin, the Client’s positions ## 56617870, 56617871, 56617872, 56618848, 56618862, 56623804, 56623805, 56623832, 56623833, 56623834, 56691961 were closed automatically, at prices available on the market (Stop Out). This fact is confirmed by the records from the server log, provided by the Broker.  

4. It is quite obvious, that from a legal standpoint the Broker acted in full compliance with the provisions of their regulatory documents. At the same time, it should be noted, that from an operational perspective it does not seem that the Broker acted in a very professional way. The Broker made the error, and only after 2 weeks fixed things opportunistically without explaining to the Client or giving them the chance to deposit additional funds or reduce their position.

5. Financial Commission is committed to the best business practices accepted throughout the industry which assume that, if there is some issue caused by the broker, there shall be minimum impact on the client, and some solutions shall be provided in a swift manner to mitigate negative effects of it on the client’s positions.

Summarizing all the above the Dispute Resolution Committee has made a decision in favour of the Client. In the general opinion of the DRC members, the Broker should bear the loss of their errors, as well as communicate much more clearly and take appropriate measures in order to avoid the occurrence of such situations on their clients’ accounts in the future. Accordingly, the Broker must fully satisfy the Client’s requirement for compensation of losses in the amount of 7000 USD incurred by the incident.

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.  

Ruled in Favor Compensation
Client 7000 USD
If you have any questions regarding this investigation, please send them to the following address [email protected]
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.
Signature Designation Date
 Anatoly Bulanov

Head of DRC

 5/03/2021

Complaint Matter

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

The Client used account # XXX (USD) for active operations with cryptocurrencies.

By the time of the incident, several Long positions were opened on the specified trading account for the ETHUSD financial instrument, with a total volume of 8890.31 micro-lots.

The incident on the Client’s trading account occurred during the flash crash on the cryptocurrency market, on February 22, 2021, at 16:23 (server time). At the specified time, as a result of a short-term surge in the volatility of financial markets and the subsequent unfavourable change in the price of the ETHUSD financial instrument, Client’s positions ## 215349578, 

215349585, 215349594, 215349606, 215349616, 215349623, 215349629, 215349635, 215349641, 

215349653, 215349660, 215349665, 215349675, 215349680, 215349687, 215349693, 215349701,

215349710, 215349717, 215349723, 215349730, 215349737, 215349743, 215349752, 215349758, 

215349766, 215349775, 215349782, 215349787, 215349794, 215349799, 215349807, 215349812, 

215349817, 215349824, 215349831, 215349836 were forcibly liquidated by the Broker due to a shortage in margin collateral (Stop Out). As a result of the incident total amount of the Client’s financial losses totalled 7343.52 USD.

According to the Client, the loss of the deposit was a direct consequence of the incorrect operation of the trading server and the illegal actions of the Broker during the incident. The Client is convinced that the liquidation of positions on the ETHUSD financial instrument by the Broker was carried out at non-market prices. As an example, the Client cites prices on Libertex trading platform, www.investing.com platform, as well as large crypto exchanges BitMEX, Binance and other independent financial service providers, where the minimum quotes for the specified financial instrument did not fall below USD 1500 during the incident. At the same time, the quotes of the Broker using Kraken crypto exchange as a liquidity provider dropped to the level of USD 997.92. The client considers such a discrepancy in prices for the same asset to be unacceptable. In the Client opinion, the Broker should act based on the market information obtained from several sources, and not be limited to only one single source, since this limits the objectivity. The Client also notes that during the incident, due to the freezing of the Broker’s trading server, the Buy Limit pending orders did not work on the Client’s trading account, as well as displayed incorrect price information on the trading platform charts.

In connection with the above, the Client requests the Dispute Resolution Committee of the Financial Commission to verify the correctness of the Broker’s actions during the incident and the correctness of the execution of the disputed transactions ## 215349578, 215349585, 215349594, 215349606, 215349616, 215349623, 215349629, 215349635, 215349641, 215349653, 215349660, 215349665, 215349675, 215349680, 215349687, 215349693, 215349701, 215349710, 215349717, 215349723, 215349730, 215349737, 215349743, 215349752, 215349758, 215349766, 215349775, 215349782, 215349787, 215349794, 215349799, 215349807, 215349812, 215349817, 215349824, 215349831, 215349836, as well as a compensation of financial losses incurred by the incident in the amount of 7343.52 USD. As documentary evidence, the Client provided screenshots of the price dynamics of the ETHUSD financial instrument during the incident, taken from the Broker’s trading platform.

In turn, the Broker does not see any grounds for the Client’s complaint, since in their opinion all Client’s positions were closed correctly, at actual market prices and in accordance with the provisions of the regulatory documents and trading rules established by the Company. The Broker provided the investigation with the trading history of the Client, the server log records, and tick data history on ETHUSD financial instrument during the incident got from the liquidity provider

Complainant Broker
XXX YYY
Financial Commission Complaint #ZZZ
Complaint Raising Date Complaint Filing Date
22/02/2021 02/03/2021
Complaint response:

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 against the background of massive actions of market participants to fix profits, after significant growth in the cryptocurrency market and the ETHUSD asset reached the psychologically important price level of 2000 USD on the eve of the incident. The growth of market volatility and, as a consequence, a significant decrease in its liquidity is a typical market reaction during a period of volatility. The client should understand that circumstances of this kind radically change the flow of quotes, since it often involves price gaps, widening spreads and slippage during order execution. The client should be aware that trading in such market conditions is accompanied by significant risks.

2. Secondly, according to the information received from the Broker, the quotation of the ETHUSD financial instrument, disputed by the Client, was received from the Broker’s liquidity provider – the Kraken crypto exchange. In turn, the history of tick data from Kraken indicates that during the incident, the Bid quotes (for which Long positions are closed) for the ETHUSD instrument on the specified exchange dropped to the price level of 690 USD. At the same time, on the Broker’s platform, the minimum value of Bid quotes is registered at 997.92 USD. The Broker explains the difference in the minimum quotes by the fact that his trading system uses filtering mechanisms that do not allow single quotes with serious deviations from the previous ones to enter the stream.

3. Thirdly, according to the trading conditions specified in the “Trading Conditions” section on the Company’s website, the Client’s account type assumes Stop Out at the level of 10%. At the time of the incident, the margin level on the Client’s trading account dropped below the critical level, and therefore the Broker forcibly liquidated the Client’s unprofitable positions. This fact is confirmed by the trade server log entries provided by the Broker. The Broker’s actions during the incident fully comply with the provisions of the Client Agreement:

12.1  In case the Margin Level on the Client’s trading account becomes equal or lower than the Stop Out value, the Company has the right to close all open positions on the Client’s trading account compulsory at the current market price without any preliminary notification and the Client’s consent. Stop Out values for all account types are specified in a comparison table of account types on the Company’s website.

4. Fourth, it should also be noted that the Client assumed the risk of a complete loss of funds in his trading account, under certain circumstances, since he did not use any restrictions on the amount of possible financial losses on open positions, although he could have done this, just as it was done by him in the case of restrictions on profit. For all disputed positions, the Client has placed pending Take Profit orders at the price level of 1676.23 USD.

5. Fifth, in the text of his complaint, the Client refers to technical problems with the Broker’s trading server and the freezing of his trading terminal, which allegedly took place during the incident. The client believes that this circumstance has deprived him of the opportunity to manage his trading account and monitor the price dynamics of the financial market. In addition, according to the Client, in the group of clients affected by this incident, there are allegedly 5% of accounts that survived the drawdown, although they used the same trading algorithm (EA). In this regard, the following should be noted:

  • Upon the Client’s request, the Broker analyzed the operation of the MT5 Pro server. According to the data collected, the Client did not submit any orders that were not executed on the day of the incident. Also, there were no unsuccessful attempts to enter the trading platform. A general analysis of the platform’s operation showed that hundreds of other clients have successfully logged into the platform and performed trading operations. These facts are confirmed by the server log entries provided by the Broker.
  • The fact that the accounts used “the same trading strategy” does not guarantee the same result. In addition, at the moment, the Broker does not have any data about other accounts that the Client said about, and, accordingly, the experts of the Committee have no opportunity to study and in any way comment on such situation. Moreover, there are many different factors that can lead to a similar outcome: for example, even if the same Expert Advisor works on two different accounts and sends orders with identical parameters, the trading results on these accounts may differ due to the difference in execution prices. Such differences, in turn, may occure for two identical orders sent at the same time.
  • It should be noted that orders are not executed on the data center, but on the trading server, which centrally executes orders from all accounts opened on it. Moreover, there is no targeted segmentation or division of customers by data centers. Any client can choose any available data center for connection, and the trading platform automatically selects a data center for the client with a minimum ping.
  • Limit orders ## 215349838, 215349839, 215349840, 215349842, 215349843, 215349844, 215349845, 215349846, 215349847, 215349848 of the Client, placed to open new Long positions, at lower prices, were activated at 16:23:03, i.e. at the same second when Stop Out occurred, but were immediately canceled because there was not enough free margin on the Client’s trading account to open the indicated positions. The trade server log entries provided by the Broker also confirm this fact:

2021.02.22 16:23:03.276   ‘37012959’: new account state: Assets: 0.00, Liabilities: 0.00, Equity -5118195.65, Margin: 585468.32, Free Margin: -5703663.97

2021.02.22 16:23:03.276   ‘37012959’: order #215349848 was canceled – not enough money for order activation [#215349848 buy limit 9.18518K ETHUSD at 1583.97]

2021.02.22 16:23:03.292   ‘37012959’: position stop out triggered [#215349836 buy 1.48346K ETHUSD 1631.75 tp: 1676.23] [#215397080 sell 1.48346K ETHUSD at 997.92] [997.92 / 1249.34]

  • The reason why the charts in different screenshots look different is that one screenshot was taken before the end of the 15-minute period in which this price was present, and the second was taken after the completion of the candlestick formation. This is the standard logic of charting on the MetaTrader platform.

6. Finally, it should also be mentioned that, in the Client’s opinion, the quotes of the Kraken crypto exchange are not an authoritative source, and the brokerage company is obliged to aggregate prices from different crypto exchanges and provide clients with average prices. According to the experts of the Dispute Resolution Committee, this request is not realistic, since prices on different crypto-exchanges tend to deviate significantly from each other, especially during periods of low volatility, such as the one that took place during the incident. It should also be noted that in a decentralized market, which is the FOREX market, each broker can offer its clients prices close to the real market, although slightly different from the prices of other brokers. This is normal practice, given the varying transaction volumes for each individual broker, the ever-changing market situation and some other factors.

Considering the above and taking into account the abnormal market conditions during the incident, as well as the documentary evidence provided by the Broker, the experts of the Committee, by a majority vote, decided in favour of the Broker. According to the decision taken, the actions of the Broker to forcibly liquidate Client’s unprofitable positions ## 215349578, 215349585, 215349594, 215349606, 215349616, 215349623, 215349629, 215349635, 215349641, 215349653, 215349660, 215349665, 215349675, 215349680, 215349687, 215349693, 215349701, 215349710, 215349717, 215349723, 215349730, 215349737, 215349743, 215349752, 215349758, 215349766, 215349775, 215349782, 215349787, 215349794, 215349799, 215349807, 215349812, 215349817, 215349824, 215349831, 215349836 during the incident were recognized by the experts of the Committee as correct and executed in accordance with the provisions of the Broker’s regulatory documents and the trading rules adopted by the Company. Also, according to the general opinion of the DRC experts, the Broker should notify its clients from which crypto-exchange the quotes are taken, so that such questions do not arise in the future.

Based on the above, the Dispute Resolution Committee does not see any violations on the part of the Broker and does not see any grounds for the Client’s complaint.

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.

Ruled in Favor Compensation
Broker None
If you have any questions regarding this investigation, please send them to the following address [email protected]
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.
Signature Designation Date
 Anatoly Bulanov

Head of DRC

31/03/2021

Complaint Matter

The Client has lodged his complaint with the Financial Commission on the following grounds:

The Client used account # XXX (USD) for active trading in Binary Options. The incident on the Client’s trading account occurred on July 10, 2020, on the day when the Broker blocked the Client’s account and annulled the financial results on transactions ## 1319057826, 1324114443, 1328236807 with crypto assets, motivating their actions by the fact that on the specified account the Client used a trading strategy based on insider information, which violates the provisions of the Broker’s regulatory documents.  

The Client does not agree with the Broker’s decision (see below) and claims that he did not violate any trading rules accepted in the Company; despite this fact, the Broker decided to block the trading account and cancel the results of the disputed transactions. In the Client’s opinion, the Broker’s actions in this situation are illegal, since no objective evidence confirming the Client’s violations was presented by the Broker, and as such, there are no reasons to block the Client’s trading account.  

In connection with the above, the Client requests the Resolution Committee of the Financial Commission to verify the legality of the Broker’s actions and requires from the Broker to unblock the trading account # 63226192, as well as to return all profits received in the course of trading operations. The Client provided the investigation with the Broker’s response to this claim, as the documentary evidence.

In turn, the Broker sees no grounds for the Client’s claim and claims that the reason for blocking the Client’s trading account and cancelling the financial results on the disputed transactions ## 1319057826, 1324114443, 1328236807 was the Client’s actions that violate the provisions of the Service Agreement:

1.4.3. […] The Client will be guided by the principles of integrity, honesty, and rationality; the Client will not take actions coordinated with other Company Clients aimed at damaging the Company; the Client will not use technical features of the quote stream update on the trading terminal and will not use software errors, defects, and vulnerabilities he discovers in the trading terminal to extract income and will not distribute the information about vulnerabilities to the third parties. The Client will not use unfair and dishonest methods or ways of making trades (transactions) with the Company; the Client will not use insider or confidential information or any other information, as a result of the use of which the Client might benefit when trading with the Company and/or that might damage the Company;

In support of their position, the Broker provided the records from the database on all transactions performed by the Client, the summary information on the Client’s trading account, the screenshots with the price dynamics of the financial instrument in the disputed transactions during the incident. In addition to the above, the Broker also provided the information on the number of transactions and the corresponding trading volumes on the Binance exchange during the incident, which, in the Broker’s opinion, confirm the fact of violations of the trading rules by the Client.

Complainant Broker
XXX YYY
Financial Commission Complaint #ZZZ
Complaint Raising Date Complaint Filing Date
12/07/2020 14/07/2020
Complaint response:

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 according to the information provided by the Broker, the values of quotations for the financial asset Bitcoin, as well as for other cryptocurrencies, are calculated according to generally accepted methods used on the Chicago Mercantile Exchange. The Broker uses data from several major online exchanges such as GDAX, Kraken, Poloniex, Bitstamp, Bitfinex and Binance. Thus, the quotes for the Bitcoin asset, broadcast by the Broker in their trading platform, react to the slightest market changes. This information is published on the Broker’s website.

2. According to the Broker, in the period from June 6 to July 1, 2020, the Client has used unfair and dishonest methods or ways of making trades (transactions) with the Company. By the foregoing Broker means the following definition of Market Abuse, adopted in the EU countries:

Market abuse by its definition is a type of behaviour when one/several market participants are involved in trading activity that gives them an unreasonable advantage. Under the EU zone definition, market abuse consists of two aspects: insider trading and market manipulation. The latter represents itself as a trading activity aimed to encourage false or misleading impressions.

3.To justify their position, according to which the Client took actions aimed at manipulating the rate of the financial instrument Bitcoin outside the Broker’s platform, due to which he immediately received a risk-free profit on the Broker’s platform, the Broker uses analytical information obtained on the Binance Exchange trading platform. According to the Broker, being the world’s largest crypto exchange with the largest volumes of crypto transactions, transactions conducted on the Binance Exchange have the greatest impact on the quotes of crypto assets on any other sites around the world and, in particular, on the quotes of such assets, broadcast in the Broker’s platform.

4. The Resolution Committee checked to what extent the Broker’s statements regarding the fact of manipulation of the price of the specified asset for profit by the Client correspond to reality. For this purpose, the Committee examined the documentary evidence and the analytical information provided by the Broker. Based on the results of the audit, the Committee came to the following conclusions:

a) Analytical information on the number of transactions and the corresponding trading volumes on the Binance exchange during the period of the incident indicates that during the specified period, the Bitcoin market did indeed experience both an increase in the total number of transactions and a relative increase in trading volume, which might have led to a short-term change in the rate of the specified asset.

b) Information from the Order Book of client orders registered on the Binance platform during the incident, referred to by the Broker, demonstrates, in the Broker’s opinion, a lack of liquidity: 

  • 31163 USD was enough to achieve a yield of -0.01% during the lifespan of transaction # 1319057826.
  • 6828 USD was enough to achieve a yield of 0.02% during the lifespan of transaction # 1324114443.
  • 99096 USD was enough to achieve a yield of 0.02% during the lifespan of transaction # 1328236807.

с) Judging by the history of the Client’s trading operations, during the period of the incident, the Client made three short-term transactions ## 1319057826, 1324114443, 1328236807 with the financial asset Bitcoin, as a result, taking advantage of the drop/rise in the Bitcoin asset rate by

-0.01%/0.02%, the Client received a total profit of 10940 USD.

d) At the time of blocking, the status of the Client’s trading account was as follows:

  • Initial deposit 4015.01 USD,
  • Withdrawal of funds 0 USD,
  • Bonus funds 4005.01 USD,
  • Account balances 19028.46 USD (4015.01 + 4005.01 + 11008.44).

5. The Committee could not provide an adequate assessment of the Client’s trading transactions, since the Broker did not provide any documentary evidence confirming the fact that this particular Client took targeted actions to change the price of the specified financial instrument on the Binance platform or somewhere else.

6. Finally, it should also be noted that several members of the Committee recognized the Broker’s arguments as insignificant since they believe that if the Broker gives the opportunity to trade options on low liquid crypto assets, then they should understand that such assets may well make significant price movements with an amplitude of up to 10 -20% per day. If the Broker wishes to reduce the risk, then they must have a well-established risk management process in place. In the absence of it, the Broker should stop offering trading in what they consider to be illiquid assets in order to prevent their clients from exploiting the vulnerability of their infrastructure in the future.

Based on the above information, the members of the Resolution Committee came to a unanimous opinion that the Broker does not have sufficient grounds to assert that the Client’s actions on the trading platform in any way violate the provisions of the Broker’s regulatory documents. The members of the Committee believe that the Broker should recognize the financial results of the disputed transactions ## 1319057826, 1324114443, 1328236807 of the Client as legitimate and unblock his trading account.

Summarizing all the above the Dispute Resolution Committee does not see any violations on the part of the Client and believes that the Broker must fully satisfy the Client’s requirements to unblock the trading account # 63226192, with the right to withdraw the initial deposit and the accrued profit in the amount of 15023.45 USD.

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.  

Ruled in Favor Compensation
Client 11008.44 USD 
If you have any questions regarding this investigation, please send them to the following address [email protected]
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.
Signature Designation Date
 Anatoly Bulanov

Head of DRC

09/08/2020

April 7th 2021, The Financial Commission today announces increases in newly filed complaints, resolved complaints, as well as awards to traders and amounts sought from member brokers for March 2021 as part of its monthly Complaints Digest. The organization also experienced a rise in trading related complaints while maintaining a steady average dispute resolution time of just 8.3 days for the month.

Key monthly highlights for March 2021:

Month Over Month Comparison

Key Takeaways

Conclusions

Renewed interest in trading global markets has continued to support demand for external dispute resolution services (EDR), as highlighted by the growth of several key metrics of the Financial Commission last month. Increases in trading related complaints suggest more traders are taking advantage of market opportunities and having issues with trade execution or pricing. Roughly 25% of all new complaints filed with the Dispute Resolution Committee (DRC) in March were valued at $1,000-$9,999, highlighting the continued importance of the organization to investigate complaints with a significant monetary value. During the month, the DRC was able to ramp up the resolution of cases with total resolved complaints rising 10% from February while maintaining a steady average resolution time of 8.3 days. 

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].

March 9th 2021, The Financial Commission announces increased amounts sought and awarded to traders, as well as average complaints values for February 2021 as part of its monthly Complaints Digest. The organization recorded a decrease in new complaints filed, but maintained a steady rate of resolved complaints, percentage awarded and several other key metrics while achieving an average dispute resolution time of just 8.3 days.

Key monthly highlights for February 2021:

Month Over Month Comparison

Key Takeaways

Conclusions

The recent trading frenzy in equities has supported the demand for external dispute resolution services (EDR), as highlighted by the growth of several key metrics of the Financial Commission in recent months, with a noticeable slowdown in February as a result of markets returning to range-bound trading in some areas. Nonetheless, compensation amounts sought by traders, as well as average complaints values and the awards to traders in February 2021 by the Dispute Resolution Committee (DRC) highlight a persistent demand for EDR services. Financial-related complaints were beaten out by non-trading complaints in February, suggesting investors are having more issues with such things as bonus policies, account blocking and customer service-related issues. During the month, the DRC was able to maintain a steady rate of total resolved complaints, down just 8% from January 2021 and in doing so resolved complaints at a speed of 8.3 days, albeit increasing this metric 46% MoM, but still keeping it well below other comparable dispute resolution services available to traders.

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].

February 19, 2021, The Financial Commission today announces execution certification for AmorFX, an approved member of the Commission using Verify My Trade, a “value-added” service launched several years ago to promote pricing and execution transparency in the Forex market.

Verified order execution quality

Following the launch of order execution verification with Verify My Trade (VMT) in September of 2018, Financial Commission broker members continue to apply for certification of their order execution quality as a step to increase transparency regarding execution speed and pricing.

Today,  AmorFX becomes the latest Financial Commission member to have successfully completed the VMT certification, having satisfied all execution quality standards set out for all members of the Commission. Trades can now view the execution audit results for  AmorFX directly on our website, by clicking here.

Check your broker’s status

All interested parties can now view the execution audit results for members of the Financial Commission using VMT certifications by visiting our Members page or the profile pages of brokers listed in our Members section. Certified brokers will be highlighted with a unique badge as displayed below.

By clicking on the badge users will navigate to a dedicated webpage for each broker that will indicate the last time an audit was performed, how many orders were analyzed, and whether the results satisfied the order execution standards established by VMT.

If you are interested in using the VMT service or would like more information, please reach out to us at [email protected].

About the Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges, and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD, and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

February 15th  2021, The Financial Commission announces continued monthly growth in submitted complaints, as well as compensation sought and awarded to traders for January 2021 as part of its monthly Complaints Digest. The organization recorded a significant increase in compensation sought, percentage of awarded compensation, complaints ruled in favour of traders and several other key metrics while achieving an average dispute resolution time of just 5.7 days.

Key monthly highlights for January 2021:

Month Over Month Comparison

Key Takeaways

Conclusions

Renewed focus on equities markets, as well as commodities, continued to garner trader interest and provide for solid trading volumes across different asset classes. The continued interest in trading has supported the demand for dispute resolution services, as highlighted by several key metrics of the Financial Commission, including new complaints filed, average complaints values and total compensation sought by traders. While financial-related complaints continued to dominate, trading complaints jumped 27% in January, suggesting investors are having more issues with regards to trade executions and pricing than at the tail end of 2020. At the same time, the Dispute Resolution Committee (DRC) was able to once again rule a significantly higher number of complaints in favour of trades in January, as cases ruled in favour of clients jumped 190% month-over-month.

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].

February 3d, 2021, The Financial Commission today announces execution certification for Lotas Capital, an approved member of the Commission using Verify My Trade, a “value-added” service launched several years ago to promote pricing and execution transparency in the Forex market.

Verified order execution quality

Following the launch of order execution verification with Verify My Trade (VMT) in September of 2018, Financial Commission broker members continue to apply for certification of their order execution quality as a step to increase transparency regarding execution speed and pricing.

Today,  Lotas Capital becomes the latest Financial Commission member to have successfully completed the VMT certification, having satisfied all execution quality standards set out for all members of the Commission. Trades can now view the execution audit results for  Lotas Capital directly on our website, by clicking here.

Check your broker’s status

All interested parties can now view the execution audit results for members of the Financial Commission using VMT certifications by visiting our Members page or the profile pages of brokers listed in our Members section. Certified brokers will be highlighted with a unique badge as displayed below.

By clicking on the badge users will navigate to a dedicated webpage for each broker that will indicate the last time an audit was performed, how many orders were analyzed, and whether the results satisfied the order execution standards established by VMT.

If you are interested in using the VMT service or would like more information, please reach out to us at [email protected].

About the Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges, and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD, and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

The Financial Commission today announces Eagle Global Markets as its newest approved Member. The company becomes the latest online brokerage to join the ranks of the self-regulatory organization, highlighting the increased interest and demand for independent external dispute resolution (EDR) services among FX industry participants.

Eagle Global Markets status as an Approved Broker Member of the Financial Commission took effect on February 2, 2021, following the approval of its membership application by the Financial Commission, thus allowing the companies and its customers access to a wide range of services and membership benefits including, but not limited to, protection for up to €20,000 per the submitted complaint, backed by the Financial Commission’s Compensation Fund.

The Financial Commission provides brokerages and their customers with an unbiased 3rd party mediation platform that helps resolve complaints in instances when parties are unable to directly come to an agreement over disputes.

For approved members and their clients participating in CFDs, foreign exchange (forex), and cryptocurrency markets, the Financial Commission helps facilitate a simpler, swifter resolution process than through typical regulatory channels such as arbitration or local court systems.

Eagle Global Markets joins a diverse range of brokerages and independent service providers (ISPs) that utilize the services of the Financial Commission and as part of their commitment to their clients while upholding membership requirements.

About Eagle Global Markets

Eagle Global Markets, registered in Nigeria with RC 1322866, was founded in 2016 to provide clients with the opportunity to access global financial markets. The broker offers a wide variety of trading assets, including currencies, precious metals, stocks, and commodities. EGM aims to educate and promote its clients into confident self-directed traders who take advantage of the company’s multi-asset and multi-device trading platform which grants an ability to access the financial markets from any place and device. Eagle Global Markets strives to deliver the most trusted, transparent, and honest service to its traders around the world.

For more information about EGM, contact them directly.

About Financial Commission

Financial Commission is an independent external dispute resolution (EDR) organization for consumers/traders who are unable to resolve disputes directly with their financial services providers that are members of the Financial Commission. The Financial Commission initially set out to provide a new approach for traders and brokers alike to resolve any issues that arise in the course of trading electronic markets such as Foreign Exchange, and then expanded into CFDs and related derivatives, in addition to certifying technology platforms used for trading.

For more information please contact us at [email protected].

January 28, 2021, The Financial Commission today announces execution certification for TitanFX, an approved member of the Commission using Verify My Trade, a “value-added” service launched several years ago to promote pricing and execution transparency in the Forex market.

Verified order execution quality

Following the launch of order execution verification with Verify My Trade (VMT) in September of 2018, Financial Commission broker members continue to apply for certification of their order execution quality as a step to increase transparency regarding execution speed and pricing.

Today, TitanFX becomes the latest Financial Commission member to have successfully completed the VMT certification, having satisfied all execution quality standards set out for all members of the Commission. Trades can now view the execution audit results for TitanFX directly on our website, by clicking here.

Check your broker’s status

All interested parties can now view the execution audit results for members of the Financial Commission using VMT certifications by visiting our Members page or the profile pages of brokers listed in our Members section. Certified brokers will be highlighted with a unique badge as displayed below.

By clicking on the badge users will navigate to a dedicated webpage for each broker that will indicate the last time an audit was performed, how many orders were analyzed, and whether the results satisfied the order execution standards established by VMT.

If you are interested in using the VMT service or would like more information, please reach out to us at [email protected].

About the Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges, and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD, and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

January 20, 2021, The Financial Commission today announces Lotas Capital as its newest approved Member. The company becomes the latest online brokerage to join the ranks of the self-regulatory organization, highlighting the increased interest and demand for independent external dispute resolution (EDR) services among FX industry participants.

Lotas Capital status as an Approved Broker Members of the Financial Commission took effect on January 20th, 2021, following the approval of its membership application by the Financial Commission, thus allowing the companies and its customers access to a wide range of services and membership benefits including, but not limited to, protection for up to €20,000 per the submitted complaint, backed by the Financial Commission’s Compensation Fund.

The Financial Commission provides brokerages and their customers with an unbiased 3rd party mediation platform that helps resolve complaints in instances when parties are unable to directly come to an agreement over disputes.

For approved members and their clients participating in CFDs, foreign exchange (forex), and cryptocurrency markets, the Financial Commission helps facilitate a simpler, swifter resolution process than through typical regulatory channels such as arbitration or local court systems.

Lotas Capital joins a diverse range of brokerages and independent service providers (ISPs) that utilize the services of the Financial Commission and as part of their commitment to their clients while upholding membership requirements.

About Lotas Capital

Lotas Capital was established in 2017 by professionals who have been at the forefront of the FX industry to bring a new pulse to the markets.  It serves 106 products including currency pairs, CFDs, stocks, cryptocurrencies. Lotas Capital aims to increase the financial literacy level of all investors with forex training, e-books, training videos, and online seminars. Lotas Capital has embraced trust, excellence in service, and diversity as founding purposes, and works to carry these principles into the future. The company’s vision is to provide the best service to customers by keeping the principle of trust which is the biggest deficiency in the Forex market

For more information about Lotas Capital, contact them directly.

About Financial Commission

Financial Commission is an independent external dispute resolution (EDR) organization for consumers/traders who are unable to resolve disputes directly with their financial services providers that are members of the Financial Commission. The Financial Commission initially set out to provide a new approach for traders and brokers alike to resolve any issues that arise in the course of trading electronic markets such as Foreign Exchange, and then expanded into CFDs and related derivatives, in addition to certifying technology platforms used for trading.

For more information please contact us at [email protected].

January 14th, 2021, The Financial Commission today announces the results of its operations for the previous year with the publication of the 2020 Complaints Summary. The organization achieved record annual growth in key metrics, as well as significant membership expansion during a challenging year impacted by the Covid-19 pandemic while maintaining a quick and efficient average dispute resolution time.

New records set in 2020

Other key metrics & accomplishments in 2020

Annual Complaints Summary

Key Takeaways

Conclusions

The Financial Commission mitigated disruptions caused by the global Covid-19 pandemic to continue providing quick and efficient dispute resolution services to traders and broker members in 2020. Market volatility events during the last year, including those in oil, gold, and equities markets provided for a hefty amount of new complaints for the organization and led to new records in operational metrics. 

The organization further expanded in the Middle East, with several new Turkish broker members, as well as the addition of a Turkish expert on the Dispute Resolution Committee. The organization’s free dispute resolution service to traders gained popularity in Asia, the Middle East, and Africa with new complaints from these regions growing 202%, 15%, and 14% respectively in 2020. The Financial Commission also saw a 17% decrease in complaints from Russia and former Soviet republics, as local market restrictions impeded the normal online trading operations FX and CFD traders have come to expect. 

The majority of complaints in 2020 were related to financial issues with 55% of the total, while trading related disputes accounted for 25%. The most popular topics for complaints dealt with funds withdrawal (31%), agreement breach (17%), price check (14%), and account blocking (6%). Of all resolved complaints, 52% were resolved “in favor of the broker” and 18% resolved “in favor of the client”, while 30% were found to be outside the organization’s jurisdiction. 

Heading into 2021, the Financial Commission sees continued global challenges from the Covid-19 pandemic, as well as political instability in the US as having a substantial impact on market prices and volatility in the near term and expects to continue to see elevated numbers of new complaints submitted by traders in 1Q 2021.  

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges, and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD, and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].

January 12th, 2021, The Financial Commission announces continued growth in submitted and resolved complaints, as well as compensation awarded to traders for December 2020 as part of its monthly Complaints Digest. The organization recorded a significant increase in resolved complaints, percentage of awarded compensation, and several other key metrics while achieving an average dispute resolution time of just 6.1 days.

Key monthly highlights for December 2020:

Month Over Month Comparison

Key Takeaways

Conclusions

Global impacts from Covid-19 continued to impact market volatility as investors looked to have embraced equity and shares Contracts for Difference (CFD) trading more so than traditional Forex. Continued interest in trading has supported the demand for dispute resolution services, as highlighted by several key metrics of the Financial Commission, including new complaints filed and total complaints resolved, average complaints values, and non-member compensation sought. While financial-related complaints continued to dominate, non-trading complaints jumped 39%, suggesting investors are having issues outside of traditional trading and funding or withdrawals. At the same time, the Dispute Resolution Committee (DRC) was able to rule a significantly higher number of complaints in favor of traders in December, as cases ruled in favor of clients jumped 100% month-over-month.

About Financial Commission

Founded in 2013, the Financial Commission is a leading independent member-driven external dispute resolution (EDR) organization for international online brokerages, exchanges, and Blockchain firms that participate in global foreign exchange (forex), derivatives, CFD, and digital asset markets.

The Financial Commission provides efficient compliance solutions to its members, alongside its External Dispute Resolution (EDR) mechanism that serves as an effective channel for processing complaints from clients of member firms.

For more information please contact us at [email protected].