Hi Propwarrior,
I am happy to address the regulatory action you mentioned along with any additional questions you may have. FXCM should have passed on positive slippage to our clients from the beginning.
For clarification, while this NFA announcement was made in 2011, the time period it relates to occurred between 2006 and 2010. FXCM took major steps to address potential conflicts of interest when we first introduced the No Dealing Desk (NDD) forex execution model in 2006, back when the vast majority of brokers in the industry were still using a dealing desk model. We made this change because we believed then and we still believe now that the NDD model is more fair and transparent in that it offers competitive, market driven prices that are sourced from
multiple liquidity providers.
In switching to the NDD model, we left behind the fixed-spread dealing desk model which was the norm at the time. This meant that our clients enjoyed benefits that weren't traditionally available to retail forex traders in the past such as the ability to set stops and limits as close as 1 pip from the market price, with no restrictions on setting orders during news events, and no re-quotes. This eliminated a lot of the potential conflicts of that can exist with the dealing desk model, and has helped FXCM grow into an industry leader with $875 billion in retail customer trading volume in the third quarter of 2016.
That's not to dismiss what happened from 2006 to 2010, and we apologize for not passing on positive slippage in full to our clients in the past. as part of our settlement with regulators regarding positive slippage, we fully reimbursed current and former clients for any positive slippage they did not receive prior to 2010. As a result of the changes we made to our execution system in 2010, FXCM now passes on all available positive slippage in full to our clients on all orders types including market and limit orders.
FXCM is regulated in the US by the CFTC and NFA, the same two bodies that oversee futures trading on the CME. In compliance with rules regarding price slippage and price re-quoting that were finalized in 2012, FXCM US provides daily trade reports to the NFA which monitors and supervises FXCM US's activity including information on the price where all client orders are filled and the corresponding price where those orders are offset with our liquidity providers.
All of FXCM's global trading entities including FXCM UK and FXCM Australia execute client rolling spot forex transactions as a riskless principal with FXCM US, so the same execution standards are applied for all of our clients worldwide.
The latest execution stats from January 2015 through March 2016 showed the following:
- 78.71% of all orders had NO SLIPPAGE.
- 12.77% of all orders received positive slippage.
- 8.52% of all orders received negative slippage.
- 50.2% of all limit and limit entry orders received positive slippage.
- 39.9% of all stop and stop entry orders received negative slippage.
By contrast, while there are no re-quotes at FXCM, there are still some brokers today that re-quote their clients. Clients of such brokers receive a re-quote when the market moves in their favor, but don't receive a re-quote when the market moves against them. It's possible that this asymmetrical application of re-quotes could cause clients of such brokers to miss out on potential positive slippage.