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Following on from last month's European attack on the City of London a new front has opened up in the war currently being waged to regulate away risk in the world's financial markets. However this time around Britain is fighting back in the courts! Bloomberg reports that:

Britain will sue the European Central Bank over plans to prevent some euro-denominated securities from being cleared outside the 17 countries that share the currency, in the first such move by a government.

In this instance the supposed problem isn't high frequency trading. Rather it's the ECB's desire not to find itself in the position of having to bail out clearing houses for euro denominated derivatives that are not located in the euro zone. According to Bloomberg once more:

Clearing houses such as LCH.Clearnet and Deutsche Boerse AG’s Eurex Clearing operate as central counterparties for every buy and sell order executed by their members, who post collateral, reducing the threat from a trader’s default.

European Union governments have discussed giving clearing houses access to central-bank liquidity as a way to prevent them from collapsing and causing a financial crisis. The European Commission said last year that access to central bank liquidity could be useful in preventing clearing houses becoming a source of risk to the financial system in themselves. It included the idea in proposals it made in September 2010 to push trading of over-the- counter derivatives through central clearing.

The ECB has said clearing activities should take place in the euro region if it is expected to provide such financial support.

The British Government doesn't see it this way however. They maintain that:

The ECB’s policy contravenes European law and fundamental single market principles. The government wants to see this resolved swiftly and without involving the courts but if necessary will not shy away from continuing legal action.

Having said all that, perhaps there is more to this war than merely reducing financial instability?

The development comes as London Stock Exchange Group Plc holds talks with LCH.Clearnet Group Ltd. to buy all or part of the world’s biggest clearing house for swaps, as increased global regulation makes the business more profitable.

Filed under Regulation by  #

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Fresh from agreeing a settlement with FXCM's UK subsidiary, the CFTC has stepped up its campaign in the courts against "unregistered" RFEDs by announcing that it is bringing civil actions against another 11 foreign currency firms. As in their first such sweep a number of those firms are based in far away places such as Belize, the British Virgin Islands and Cyprus. However two names stand out in the CFTC's blacklist of miscreants as being more "onshore" than the others, namely:

City Credit Capital, (UK) Ltd., a United Kingdom company;

and:

Enfinium Pty Ltd., an Australian company;

Both actions have been filed in "the United States District Court for the northern district of Illinois eastern division" rather than in the UK or Australian courts. Enfinium acquired Australian broker Vantage FX last year, and it is the Vantage name that the CFTC cite in their complaint. More recently a significant stake in Enfinium was acquired by China Private Equity Investments Holdings Limited who are listed on the London Stock Exchange's AIM market, and were thus happy to announce recently on the LSE's Regulatory News Service that:

The Board of CPE is delighted to announce that the title "Best Forex Broker in South East Asia" has been awarded to the forex broking arm of Enfinium International Holdings Limited ("Enfinium"), in which CPE recently acquired a 30% stake.

The prestigious accolade, won in competition against nearly 140 other international brokers participating in the 2011 IBTimes Trading Awards in New York City, went to Vantage FX, a Corporate Authorised Representative of Enfinium. VantageFX also collected a "Forex Broker Australia – Excellence Award".

The IBTimes Trading Awards claims to be the most comprehensive annual award series within the fast-growing retail forex market.

In both cases the CFTC alleges that:

Beginning on October 18, 2010 and continuing to the present (the “relevant period”), [the firm] solicits or accepts orders from non-ECPs located in the United States in connection with retail forex transactions and is, or offers to be, the counterparty to these retail forex transactions without being registered as an RFED with the CFTC, in violation of Section 2(c)(2)(C)(iii)(I)(aa) of the Act, as amended, to be codified at 7 U.S.C. § 2(c)(2)(C)(iii)(I)(aa) and Regulation 5.3(a)(6)(i), 17 C.F.R. § 5.3(a)(6)(i).

and that:

Venue properly lies with the Court pursuant to Section 6c(e) of the Act, as amended, to be codified at 7 U.S.C. § 13a-1(e), because [the firm] transacts business in this District and certain transactions, acts, practices, and courses of business alleged in this Complaint occurred, are occurring, and/or are about to occur within this District.

Whilst Vantage FX may not be registered in the U.S. as an RFED, they are registered with the Australian Securities and Investments Commission. The Vantage FX name is even registered here in the UK as well, although this is just a licence to use the brand and the two companies have no other legal connection. Whatever else they may be, CPE/Enfinium/Vantage are certainly not a run of the mill offshore bucket shop. Neither are City Credit Capital (UK) Ltd for that matter. They too are currently registered in the UK with the Financial Services Authority, and on their website they proclaim that:

The senior management team at City Credit have worked across the globe and have been drawn together from some of the world's premier financial institutions including HSBC, Citigroup and Société Générale.

It looks as though neither Enfinium or City Credit are rushing to follow in FXCM's footsteps and cough up a few hundred grand to settle matters with the CFTC. Meanwhile here at the Trading Gurus we're eagerly waiting to discover how these actions taken by the CFTC in the US courts might result in sanctions against offshore FX brokers that are properly registered within their own jurisdictions and who aren't so eager to reach a quick settlement. In their latest press release the CFTC has this to say about their first batch of court actions:

With respect to the similar actions filed in January 2011, 11 of the 14 defendants have either settled the charges or defaulted, and the charges against the remaining three are pending.

The CFTC strongly urges the public to check whether a company is registered before investing funds. If a company is not registered, an investor should be wary of providing funds to that company.

Filed under Regulation by  #

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At the request of one of our loyal readers we've just opened up a new section on the Trading Gurus community forum devoted to Artificially Intelligent Trading.  As other loyal readers will know, here at the Trading Gurus we love Ray the Random Robot and his particular brand of Artificially Stupid Trading. However we're also very open minded, not to mention modest! Apart from anything else we're keen to discover how other sorts of "robots" go about earning their keep. Some interesting debates have already started on the forum, where Pippa has recently revealed some very interesting news.

Starting on October 10th 2011 the Stanford University School of Engineering is running:

A bold experiment in distributed education, "Machine Learning" [and "Introduction to Artificial Intelligence"] will be offered free and online to students worldwide during the fall of 2011. Students will have access to lecture videos, lecture notes, receive regular feedback on progress, and receive answers to questions. When you successfully complete the class, you will also receive a statement of accomplishment.

Ray is certainly very interested in learning some new trading tricks, and he wondered if you might be as well. Here's a video to give you some idea about what's on the curriculum:

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My attention has recently been drawn to an academic research paper entitled High Frequency Trading and The New-Market Makers. The author, who is from the VU University in Amsterdam, investigates the connection between high frequency trading and the emergence of new exchanges here in Europe:

It shows how the success of a new market, Chi-X, critically depended on the participation of a large HFT who acts as a modern market-maker. The HFT, in turn, benefits from low fees in the entrant market, but also uses the incumbent market Euronext to offload nonzero positions.

To summarise the findings:

One particular set of broker IDs matched across markets shows the characteristics of an HFT that acts as a market maker in both the entrant market (Chi-X) and the incumbent market (Euronext). In each market, four out of five of its trades are passive, i.e., the HFT was the (liquidity-supplying) limit order in the book that got executed.  It makes money on the spread but loses money on its positions. If this positioning loss is decomposed according to duration, one finds that positions that last less than five seconds generate a profit whereas the ones that last longer generally lose money. The HFT is equally active in both markets as roughly half of its trades are on Chi-X and the other half are on Euronext.

and:

The paper shows how fees are a substantial part of a high-frequency trader’s profit and loss account. It is therefore not surprising that new, low-fee venues have entered the exchange market as they are attractive to these ‘modern’ market makers. It is shown that such lower fees are, at least partially, passed on to endusers through lower bid-ask spreads. This evidence adds to the regulatory debate on high-frequency traders and highlights that a subset is closely linked to the rapidly evolving market structure that is characterized by the entry of many new and successful trading venues.

This research seems to suggest that high frequency trading is actually a good thing, both for the "New-Market makers" themselves and the beneficiaries of the resulting lower bid-ask spreads on new exchanges such as Chi-X.

However this view doesn't seem to be held by regulators on both sides of the Atlantic, since as we discussed back in 2009, both SEC chairman Mary Schapiro and the then UK "City minister" Lord Myners held the view that:

We need a deeper understanding of the strategies and activities of high frequency traders and the potential impact on our markets and investors of so many transactions occurring so quickly. And we need to consider whether there are additional legislative authorities needed to address new types of market professionals whose activities may not be sufficiently regulated.

It seems as though the US legislative authorities have been as good as their word, since one of the references at the back of HFT & The New-Market Makers is another academic paper. This one is entitled "The Flash Crash: The Impact of High Frequency Trading on an Electronic Market", and the authors hail from another US regulator. In this case it's the CFTC. They conclude:

Based on our analysis, we believe that High Frequency Traders exhibit trading patterns inconsistent with the traditional definition of market making. Specifically, High Frequency Traders aggressively trade in the direction of price changes. This activity comprises a large percentage of total trading volume, but does not result in a significant accumulation of inventory. As a result, whether under normal market conditions or during periods of high volatility, High Frequency Traders are not willing to accumulate large positions or absorb large losses. Moreover, their contribution to higher trading volumes may be mistaken for liquidity by Fundamental Traders.

We conclude that HFTs did not trigger the Flash Crash, but their responses to the unusually large selling pressure on that day exacerbated market volatility.

Not exactly the same conclusion as the Dutch paper then, and not exactly a clean bill of health either. However exacerbating market volatility isn't quite the same thing as destroying Western capitalism as we know it.

Not content with leaving these matters to the Anglo Saxons, it seems Angela Merkel and Nicolas Sarkozy have been discussing similar issues recently. According to the Daily Telegraph Mr Sarkozy said:

The French and German ministers will table a joint proposal at EU level next September for a tax on financial transactions. This is a priority for us.

This so called "Tobin Tax" has been previously mooted as one way of making high-frequency trading unprofitable, and thereby ridding the world of its menace once and for all. According to the Telegraph once more:

The plans by Germany and France to introduce a financial transaction tax (FTT) could raise a total €80.9bn (£70.7bn) – of which €58.3bn would come from UK-based businesses.

As you may be able to imagine, this Continental concept hasn't gone down too well with some of the aforementioned UK-based businesses. In particular Michael Spencer, founder and CEO of ICAP and last year's Ernst & Young World Entrepreneur Of The Year, seems to have taken a very dim view of it. According to Mr. Spencer:

This tax would destroy the City and cost the Exchequer billions, but it would benefit Brussels. Companies like ICAP will simply move elsewhere outside the EU if Nicolas Sarkozy and Angela Merkel push ahead with this silly tax.

Unlike their Labour predecessors, it seems as though the current Tory government isn't wild about the plan either:

Last week, Treasury sources signalled that Britain would be prepared to veto such a tax if Paris and Berlin succeed in bringing the plan to a vote among 27 EU members.

I'm sure that Mr. Spencer's donations to the Tory party have no bearing on any of that, but all these conflicting signals are nonetheless terribly confusing.  If you're currently an Anglo Saxon high frequency trader now would seem like a prudent time to consider plan B, if you haven't done so already.

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Yesterday evening customers of UK spreadbet and forex/CFD broker Smart Live Markets received an email announcing that:

Smart Live Financial Services Ltd will be changing its name in the coming weeks to GKFX Financial Services Ltd.

According to the email:

The reason for this change is cosmetic.  As we have grown globally as a company it has been apparent that some people have been confused by our name, so we have chosen a more generic name which as a brand going forward will be far more easily recognised throughout the world.

When I enquired about why such a "cosmetic" change was necessary I was told that the Smart Live brand is associated in many people's mind with the gaming industry, and that such an association is likely to be a hindrance to the expansion of Smart Live/GKFX in the Middle East. It seems that while spread betting is classified as gambling in the UK, trading forex and CFDs is not in the rest of the world (or in the UK for that matter!).

When I further enquired about the significance of the GKFX  name I was told it was a four letter domain name ending in FX that happened to be available.  According to Smart Live's entry in the FSA register it stands for Global Kapital FX, but apparently for some reason no marketing will be done using that version of the new name!

Filed under Brokers by  #

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Fresh from having their UK subsidiary fined by the CFTC earlier this month, FXCM have now been fined $2 million by the National Futures Association. Once again the complaint against FXCM and their CEO Drew Niv and details of the agreed settlement have been published simultaneously. Once again FXCM neither admit nor deny the allegations in the complaint, which concern FXCM's failure to pass on positive slippage from their liquidity providers to their customers, and lapses in their anti money laundering procedures. However this time around FXCM's customers do stand to benefit financially since one of the agreed sanctions states that:

Within 30 days of the effective date of this decision, FXCM shall make a good faith effort to credit the accounts of its customers the amount of positive slippage which its customers experienced on their trades from and after June 18, 2008

More on FXCM Fined $2 million by the NFA

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AlgoTrader today announced a new open source algorithmic trading platform. AlgoTrader is an automated trading system that can trade any type of security on any market available through Interactive Brokers and/or the FIX protocol (real soon now!). All aspects of trading such as obtaining market data, analyzing prices, taking trade decisions, placing orders & tracking executions can be automated. The new platform uses the Esper complex event processing engine, and is based on Java SE 6.0, Spring, and a Model Driven Architecture.

An initial version of AlgoTrader is now available Open Source at http://code.google.com/p/algo-trader/

Features of the system include:

  • Automates trading strategies based on trading rules (using Esper EPL)
  • Automated execution via different broker interfaces
  • Backtesting and simulation of trading strategies based on historical data
  • Portfolio tracking & performance measurement

In the interests of transparency I should point out that I'm a member of the AlgoTrader development team. If you are interested in contributing to the project too then please get in touch.

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Last October we wondered what steps the CFTC would be able to take to enforce the new forex trading regulations that had just come into force, particularly when it came to pursuing offshore brokers in offshore courts.  Back in January they sued a few brokers using the US courts. Now they have used a different approach, which still hasn't required the CFTC to state their case in a foreign jurisdiction. It seems all they need to do is to ask nicely for some money!

The CFTC has just announced that it has:

Filed and simultaneously settled charges that Forex Capital Markets Ltd. (FXCM Ltd.) of London, U.K. acted as a retail foreign exchange dealer (RFED) by conducting retail leveraged forex transactions with U.S. customers without registering with the CFTC under the agency’s regulation 5.3(a)(6)(i). FXCM Ltd. has never been registered with the CFTC in any capacity.

The CFTC order requires FXCM Ltd. to pay a $140,000 civil monetary penalty and to cease and desist from further violating CFTC regulation 5.3(a)(6)(i).

According to the CFTC order instituting proceedings:

The Commodity Futures Trading Commission ("Commission") has reason to believe that from October 18,2010 to October 29, 2010, Forex Capital Markets Ltd. ("FXCM Ltd." or "Respondent") violated Commission Regulation 5.3(a)(6)(i), to be codified at 17 C.F.R.§ 5.3(a)(6)(i). Therefore, the Commission deems it appropriate and in the public interest that public administrative proceedings be, and hereby are, instituted to determine whether Respondent engaged in the violation set forth herein and to determine whether any order should be issued imposing remedial sanctions.

Whether in the public interest or the interest of their shareholders FXCM seem to have thought it was prudent to settle this issue without getting as far as a court in either the US or the UK. According to the CFTC order once more:

In anticipation of the institution of an administrative proceeding, Respondent has submitted an Offer of Settlement (the "Offer"), which the Commission has determined to accept. Without admitting or denying any of the findings or conclusions herein, Respondent consents to the entry of this Order Instituting Proceedings Pursuant to Sections 6(c) and 6(d) of the Commodity Exchange Act, As Amended, Making Findings and Imposing Remedial Sanctions ("Order") and acknowledges service of this Order.

Nothing's been admitted or proven, but FXCM UK have agreed to become a bit poorer, and the US authorities a bit richer.  How is any of this in the interests of the members of the US public who allegedly placed some trades via FXCM UK during those 11 days last October?

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In a press release yesterday Saxo Bank announced that their ForexTrading.com web site not only provides some forex trading education. It now also allows you to trade spot forex and CFDs:

Saxo Bank, the online trading and investment specialist, today announced the launch of ForexTrading.com which will offer retail investors a select range of FX crosses and CFDs with variable spreads – as low as 0.8 pips.

Those spreads are not only variable, they are also significantly smaller than the spreads available to Saxo's existing retail clients through the SaxoTrader and WebTrader platforms. Here's a quick comparison between two demo accounts, with the new ForexTrading.com first:

ForexTrading.com FX Quote Board

ForexTrading.com FX Quote Board

Saxo Bank FX Quote Board

Saxo Bank FX Quote Board

Something else that has reduced is the minimum initial deposit, which is down to $2,000 for the new accounts.  Obviously there is a price to be paid for these benefits. You  trade using  cut down versions of SaxoTrader and/or WebTrader, which only allow you access to a limited selection of the most liquid FX pairs (both spot and forward) and commodity CFDs:

ForexTrading.com available FX pairs

ForexTrading.com available FX pairs

ForexTrading.com available CFDs

ForexTrading.com available CFDs

If you want to trade stocks, futures or options you'll still need a "classic" Saxo account. If you can live without those instruments however, on a ForexTrading.com account all communications will have to be in English, and trading is not available via telephone.  The new accounts have to be funded by wire transfer initially, but after that instant top-ups using debit or credit cards are available. That might come in handy, since leverage on the most liquid pairs can go as high as 1:200! You might well infer from that fact that these new accounts are not available to citizens of the United States, and you would be correct to do so.

Assuming you're not from the U.S. and you've funded your account there are a numbers of ways of placing a trade, but all of them are manual! Once upon a time Saxo did support automated trading via Trade Commander, but not any more it seems. We took a look at Saxo's Web Trader platform when MSN Trader was launched, so for now we're going to concentrate on the desktop platform. Here's a view of an FX order ticket:

ForexTrading.com FX Order Ticket, including DoM

ForexTrading.com FX Order Ticket, including DoM

As you can see there are a variety of ways of entering a variety of order types, and on FX at least market depth information is made available to you. Minimum order size for forex is 5,000 – midi lots I suppose?

If all that information seems like it's too much to handle, you can look at a table of your favourite instruments instead:

ForexTrading.com "Prices & Trade" view

ForexTrading.com "Prices & Trade" view

If you click the little "Trade" check box the quotes turn into green buttons, and you can perform a one click trade by just clicking one of them. Note too that "Gold" is available either as spot "FX" or as a futures style CFD complete with expiry date. That no doubt explains why the "Value Date"  box which allows you to select a forward date for FX pairs is grayed out for gold. Along with the other commodity CFDs, there is also a "continuous" version of gold of the sort familiar to futures traders.  This merges the different contract expiries into a single set of data that can be charted and/or analyzed without any sudden jumps at expiry, but can't be traded.

There you have our first quick impressions of Saxo Bank's new retail brokerage offering. It looks like it's going to be worth a very close look at a practice account if you're happy trading manually and you have in your possession at least $2,000 you're willing to lose. However if you're into automated forex trading like us, or you're from North America, unfortunately you'll need to look elsewhere. As things stand at the moment ForexTrading.com isn't going to see off MetaQuotes.net just yet.

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If you're from the United States you may well never have heard of Buru Trader. However if you're a customer of Interbank FX Australia like me, you probably will have done. It's a bundle of two MetaTrader 4 expert advisors called "buru New York" and "buru Tokyo", which IBFX Australia have been promoting over the last few months.  On March 15th IBFX were inviting their customers to find out about:

An exclusive MT4 Expert Advisor Buru, powered by our revolutionary technology

and suggesting that you might like to:

Revolutionise your trading. IBFX Australia is the exclusive execution platform for Buru, the MT4 EA that has consistently earned impressive gains since June 6, 2010:

* Average Weekly Return: +2.5%*

* Average Monthly Return: +10.7%*

* Full History of 267 days: +151.06%*

Buru is an EA that requires the cutting-edge proprietary technology found with IBFX Australia.

* Past performance is not necessarily indicative of future results. Individual results may vary.

That last point certainly seems to have been rather prescient, since whatever the merits of Interbank FX's cutting-edge technology Buru itself has turned out to be anything but revolutionary. According to an email I received from IBFX Australia on March 14th:

Prior to partnering with IBFX Australia, Buru's system was tested with multiple MT4 brokers. The results were far from satisfactory until IBFX Australia surpassed expectations with their live account performance, superior execution and liquidity management.

Even in partnership with IBFX Australia, the results of Buru's system(s) have now proved to be far from satisfactory once again.  Initially Buru Partners were keen that prospective purchasers of their EAs should view some "Customer Live Account Statistics". As you can see, that page currently doesn't seem to be working properly.  However there are still some "live" statistics visible on the Buru home page, which look like this at the moment:

Buru New York EA Live Statistics on May 20th 2011

Buru New York EA Live Statistics on May 20th 2011

Click the image to see more detailed statistics about "an independent customers live account" courtesy of myfxbook.  According to myfxbook the loss on this account currently stands at $151,712.99. It looks as though you need some very deep pockets indeed to be able to let Buru Trader loose on your account without the "robot" wiping it out for you!  For another perspective on what seems like a big problem with Buru we did some backtesting here at Guru Towers, using version 1.2 of the Buru New York EA on the EUR/USD pair with the default "Risk Factor" of 0.5 and starting on June 6th 2010. This is what we discovered:

Buru New York backtest from June 6th 2010

Buru New York backtest from June 6th 2010

The first thing to note is that a taste of things to come had already occurred on December 17th 2010, when the largest trade size rose to 3.25 and the backtest balance briefly plummeted. The second thing to note is that the backtest finished prematurely at 3:56 on May 2nd 2011, by which time the maximum open trade size had risen to 5.84. That trade was "closed at stop" along with the other 22 that were open at the time.

Next we took a look at Buru Tokyo, again using the default settings over the same period of time and on the EUR/USD pair. This is what the MT4 strategy tester revealed:

Buru Tokyo backtest results on EUR/USD

Buru Tokyo backtest results on EUR/USD

This time around it looks like Buru Tokyo decided to short the euro early on the morning of April 19th. Inconveniently for Buru users the euro then decided to rally. As it did so Buru Tokyo kept on selling in ever greater size, all the way up until at 8:48 the following day it finally decided to cut its losses and closed all 13 shorts for a loss of around half the account.

What is the moral of this cautionary tale?  Take a look at Ray the Random Robot's equity curve, which you can find handily located just to the top left of this post.  Click on it if  you'd like to check out some more detailed statistics courtesy of myfxbook. Amongst other things Ray demonstrates how easy it is for even the dumbest of "robots" to produce an impressive looking equity curve that keeps on looking impressive for far longer than the 30 day money back guarantee period offered by Buru Trader, or even the 60 days that comes with some other expert advisors.  Ray's "secret" is the same as Buru's. They both increase their trade size after taking a loss. Ray uses a fixed stop loss and martingale money management, whereas Buru uses a grid system with no traditional stop losses, but the end result is the same. The problem is that when you eventually suffer an extended sequence of losses with such robots you'll find you need to hurriedly fund your trading account with large quantities of cash to avoid disaster. If you're unable to do that you'll just have to look on helplessly as your account rapidly disappears before your very eyes, assuming you're awake at the time that is.

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