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Should You Consider Using A Forex ECN Platform? - MB Trading

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RETAIL e-FX CLIENT<br />

>>><br />

<strong>Should</strong> you consider using<br />

a <strong>Forex</strong> <strong>ECN</strong> platform?<br />

the middle of the bridge, says Layth Sanjaq, head<br />

of operations at FXCBS. On one side, there are the<br />

banks quoting prices into the client terminals through<br />

the broker’s platform. On the other side, there are the<br />

traders (clients) performing trades on those streamed<br />

prices. Each trade goes through the broker’s platform<br />

to the corresponding bank that quoted the price and<br />

gets executed using the liquidity provided by the bank.<br />

To find out if you really are trading on an <strong>ECN</strong>, says<br />

Ross Ditlove, CEO of <strong>MB</strong> <strong>Trading</strong>, there is a very<br />

simple test that can be employed. Ditlove explains:<br />

“Find any currency pair on any broker’s system. For<br />

simplicity, use a pair with a three or more pip spread.<br />

Let’s say the Bid is 100 and the Offer is 103. Now<br />

enter an order to Buy at 101. If you and everyone else<br />

on your broker’s system do not immediately see your<br />

new Bid at 101, thus making the market now 101 by<br />

103, then you are not on a true<br />

<strong>ECN</strong>. It’s that simple.” Without<br />

displaying your order immediately<br />

or at all for everyone in the system<br />

to see and act on, your broker is<br />

somehow manipulating the quote<br />

behind the scenes, says Ditlove.<br />

“<strong>MB</strong> <strong>Trading</strong>’s revenue is generated<br />

from the commission we charge the<br />

retail client, and thus we offer full<br />

transparency without manipulating the<br />

spread or quote,” he continues.<br />

Why DD and NDD?<br />

The reason some brokers now offer both dealing<br />

desk (DD) and non-dealing desk (NDD) FX trading<br />

facilities, says Giuseppe Zagara, managing partner and<br />

the co-founder at Fastbrokers.com, because NDD<br />

It is important to first define the<br />

term <strong>ECN</strong>. Traditionally <strong>ECN</strong> stands<br />

for Electronic Communications Network,<br />

a term that came from the (then) new<br />

electronic means of connecting to the<br />

NASDAQ market place. Since FX<br />

lacks both a central global exchange<br />

and market handling rules, brokers<br />

have begun to stretch the definition to<br />

<strong>ECN</strong> to suit their particular systems.<br />

Heather McLean<br />

<strong>Forex</strong> <strong>ECN</strong> platforms sound in theory like the ultimate<br />

utopian environment for trading. They can<br />

provide a place where orders are matched in real<br />

time in a collective bubble of liquidity provided<br />

by each of the market’s participants. However, as<br />

Heather McLean discovers, there is more to the<br />

world of the <strong>ECN</strong> than meets the eye.<br />

What is an <strong>ECN</strong>?<br />

Vladimir Kisyov, head of business development<br />

at Deltastock, adds to the definition: “The <strong>ECN</strong><br />

basically provides a marketplace where individual and<br />

institutional traders, market makers (MM), prime<br />

brokers and banks trade against each other by placing<br />

competing bids and offers, thus generating liquidity<br />

into that electronic system. The <strong>ECN</strong> environment<br />

allows clients’ orders to interact with other clients’<br />

orders. All trade orders are matched between<br />

counterparties in real time.”<br />

The FX <strong>ECN</strong> model can be described as a two way<br />

bridge where the broker is the traffic coordinator in<br />

“The FX <strong>ECN</strong> model can<br />

be described as a two way<br />

bridge where the broker is<br />

the traffic coordinator in<br />

the middle of the bridge”<br />

124 | april 2010 e-FOREX april 2010 e-FOREX | 125


RETAIL e-FX CLIENT >>><br />

because it requires advanced requirements in terms of<br />

technology, an excellent IT infrastructure and can bear<br />

high development costs, he adds.<br />

Vladimir Kisyov<br />

“The <strong>ECN</strong> environment allows clients’ orders to interact<br />

with other clients’ orders. All trade orders are matched<br />

between counterparties in real time.”<br />

is the answer to the growing number of FX traders<br />

demanding more transparent and fair pricing.<br />

He comments: “Retail <strong>Forex</strong> is today a mature product<br />

and traders understand its logistics (including the fact<br />

that pricing and trades are often handled in a market<br />

making environment). While there are still a few<br />

brokers using ambiguous statements about the nature<br />

of their retail forex system, most brokers are now<br />

offering a variety of trading environments to satisfy<br />

the growing demand of alternative products, often in<br />

place of the classic dealing desk.”<br />

Changing expectations<br />

“Today, we see a significant change in terms of<br />

clients’ expectations,” Vedikhin points out. “Clients<br />

from all backgrounds, including retail, are becoming<br />

increasingly demanding with regard to the suite of<br />

services they are being offered by their broker. All<br />

traders are now requesting institutional-level execution<br />

speeds, and NDD execution helps us to deliver on<br />

that. While approximately only 5% of retail clients<br />

trade via <strong>ECN</strong>s today, we expect this to grow to over<br />

95% within the next few years. The benefits of <strong>ECN</strong><br />

trading, including transparency, deep liquidity, market<br />

depth and NDD execution, will then become available<br />

to everyone.”<br />

On brokers offering both DD and NDD FX trading<br />

facilities, Kisyov says the number of NDD FX trading<br />

facilities (either STP or <strong>ECN</strong>-STP brokers) has<br />

notably increased in the last couple of years or so. He<br />

comments: “The shift from the DD to NDD business<br />

model has accurately addressed the growing needs of the<br />

forex trading community for greater liquidity and best<br />

execution, thus explaining the major migration of retail<br />

clients from MMs to <strong>ECN</strong>-STP brokers. Nonetheless,<br />

the DD model still provides advantages to traders.”<br />

“The logical consequence has been to see brokers<br />

offering an <strong>ECN</strong>-style environment. However,<br />

few brokers really allow their clients to trade these<br />

products, but simply made a major switch from the<br />

‘fixed’ spread model to a ‘floating’ spread pricing<br />

which they marketed as a ‘NDD’ or ‘multi bank’ feed.<br />

Unfortunately these are merely DD-based systems<br />

which simulate or replicate the floating bid and ask of<br />

a true <strong>ECN</strong> model, but execute orders on a DD basis,”<br />

states Zagara.<br />

Andrey Vedikhin, CEO of Alpari (UK), agrees that<br />

most brokers would like to be in a position to offer<br />

NDD execution because it allows for a much greater<br />

level of automation when matching trades. However,<br />

NDD execution is relatively difficult to achieve<br />

Giuseppe Zagara<br />

“..most brokers are now offering a variety of trading<br />

environments to satisfy the growing demand of alternative<br />

products, often in place of the classic dealing desk.”<br />

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RETAIL e-FX CLIENT >>><br />

Sanjaq continues: “I believe that brokers who are<br />

offering both DD and NDD are actually DD brokers<br />

trying to catch the trend by promoting NDD trading<br />

for their clients. The DD-NDD dilemma is ethical<br />

and can not be taken as a variety of services. Since an<br />

<strong>ECN</strong> broker’s role is to give individual traders access<br />

to the interbank market, they do not benefit from<br />

the spreads or the losses of their clients. Therefore,<br />

they usually charge a commission fee per transaction<br />

proportional to the trade size. Besides, banks<br />

usually charge the <strong>ECN</strong> broker commission fees for<br />

transaction executed on their end.”<br />

Wolf in sheep’s clothing?<br />

While Ditlove comments: “This is an example of<br />

a wolf in sheep’s clothing. If your broker does not<br />

immediately display your bid or offer for all other<br />

clients to see, if your broker maintains minimum<br />

fixed spreads, if your broker knows information about<br />

your order that is not fully transparent to the rest of<br />

the marketplace and retail traders alike, then you’re<br />

not getting a fair deal. Just because someone calls<br />

themselves a NDD-<strong>ECN</strong> does not make them so.<br />

Frankly, it’s laughable.”<br />

Yet the debate about dealing desks and non dealing<br />

desks (NDD) is a red herring, claims Glenn Stevens,<br />

CEO at GAIN Capital. He says as a retail trader, your<br />

Andrey Vedikhin<br />

“While approximately only 5% of retail clients<br />

trade via <strong>ECN</strong>s today, we expect this to grow to<br />

over 95% within the next few years.”<br />

primary concern should be your ability to get into a<br />

trade quickly and at the rate you request, and where<br />

your orders are filled. These things can positively or<br />

negatively impact your trading results; where your<br />

order is ultimately routed does not.<br />

Stevens explains: “Our belief is that NDD’s came<br />

about in response to complaints about the poor<br />

execution quality at some of the retail brokerages.<br />

Promoting themselves as a NDD was a way for<br />

brokers that entered the market late to differentiate<br />

themselves. It’s fairly well known that when the first<br />

NDD firms came on the scene there were several<br />

firms with poor reputations for execution, especially<br />

where they filled their client’s stop loss orders. Also,<br />

some brokers prefer the NDD model because it’s<br />

much easier to take a price feed from a bank, mark<br />

it up to the retail customers, then push all the trades<br />

back to the bank, than to act as a MM and manage<br />

risk internally while providing the best client dealing<br />

experience possible.”<br />

Continuing, Stevens states that GAIN Capital believes<br />

an experienced, professional trading desk is the real<br />

benefit to its retail clients at FOREX.com. “We don’t<br />

have an arm’s length relationship with our clients; we<br />

take full responsibility for the prices we quote and<br />

where we fill orders.”<br />

Conflict of interest<br />

In a pricing basis model, also known as a MM model,<br />

the prices are streamed from data vendors directly<br />

to the client terminals. Clients perform trades on<br />

the streamed prices, but the trades reach a dead end,<br />

which is the MM’s servers. Meanwhile, the dealers<br />

of the MM are trying to negotiate execution for the<br />

favour of the MM and to minimise the profitability<br />

of their clients. Sanjaq states this model creates a<br />

huge conflict of interest between the broker and their<br />

clients, as the loss of the client is considered as pure<br />

profit for the broker.<br />

He states: “As a client trading on MM’s platform,<br />

when you are buying a currency pair, the MM is<br />

your counterparty (selling to you). Therefore, if your<br />

buying order goes in profit of $1000 for example, it<br />

means that the MM is losing $1000. It’s as simple as<br />

that, unless the MM has a risk management policy<br />

that it applies to offset your order with a different<br />

counterparty at a certain point. Slippage and<br />

requotes are techniques used by MMs to minimise<br />

the profitability of the client. Scalping is usually not<br />

allowed by MMs because it gives the client higher<br />

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RETAIL e-FX CLIENT >>><br />

a day; it’s not feasible that we would or could trade<br />

against individual clients,” Stevens concludes.<br />

Not robbers<br />

On possible conflicts of interest in order execution that<br />

can occur with MMs, Kisyov says: “Market makers<br />

literally make the market for traders. They sell to<br />

buyers and buy from sellers by quoting fixed spreads.<br />

Unfortunately, most of the MMs quote variable spreads<br />

now. Market makers have been growing in number<br />

since the dawn of retail FX. I don’t think they could<br />

have survived if they had robbed clients’ accounts,<br />

especially in this highly regulated environment, where<br />

clients’ interests have been strictly protected.”<br />

Glenn Stevens<br />

“..some brokers prefer the NDD model because<br />

it’s much easier to take a price feed from a bank,<br />

mark it up to the retail customers, then push all the t<br />

rades back to the bank, than to act as a MM ...”<br />

chances of closing in profit few pips away from the<br />

opening price, which is inevitable loss for the MM.”<br />

Vedikhin states that some FX brokers are criticised<br />

by retail investors for having a conflict of interest<br />

when executing client orders; they sometimes have to<br />

become the counterparty to their own clients’ trades.<br />

However, most of this criticism is unwarranted, he<br />

claims, because the majority of clients trade with<br />

brokers that are fully licensed and regulated by various<br />

agencies such as the FSA and NFA. “Regulated firms<br />

like Alpari (UK) must abide by rules regarding best<br />

execution and treating the customer fairly at all times.<br />

This prevents any wrongdoing on behalf of the broker<br />

because regulated brokers are put under immense<br />

scrutiny by their respective regulator,” he says.<br />

Stevens agrees: “One of the biggest myths promoted<br />

by NDD brokers is that DDs are somehow ‘trading<br />

against’ clients. This is hype. At GAIN, we’re a hybrid<br />

model. We offset a potion of our trades immediately<br />

in the interbank market. Everything else is our ‘net<br />

customer exposure’ and managed on an aggregate<br />

basis. We maintain strict position limits and hedge our<br />

exposure in the interbank market as needed, according<br />

to our risk management guidelines. In certain cases,<br />

we may offset customer trades immediately in the<br />

interbank market. We process well over 100,000 trades<br />

While Jesse Richards, a registered broker and a<br />

principal at Fastbrokers.com, comments: “When the<br />

broker is on the other side of each trade, there is a<br />

conflict of interest as that broker will lose money if the<br />

client profits (if the broker does not hedge its risk),<br />

therefore the broker may be more profitable if the<br />

trader makes bad trades. I believe that the majority of<br />

deals done at NFA-regulated FDMs are done so on an<br />

ethical basis, however there are many unscrupulous<br />

brokers that actively manipulate the price to their<br />

advantage and to the disadvantage of the trader. The<br />

conflict of interest manifests itself in the execution of<br />

orders. The two most common forms of manipulation<br />

Layth Sanjaq<br />

“Scalping is usually not allowed by MMs because<br />

it gives the client higher chances of closing in<br />

profit few pips away from the opening price,<br />

which is inevitable loss for the MM.”<br />

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RETAIL e-FX CLIENT<br />

>>><br />

traders complain about are stop hunting and spread<br />

widening.”<br />

Richards adds stop hunting is the practice of a MM<br />

moving the price to hit a large number of protective<br />

stop orders, even if the price may not have reached<br />

that level through competitive pricing. In this scenario<br />

the MM pushes the price up or down by a few pips<br />

momentarily with the intent of stopping out traders<br />

and booking profits for the dealer. Spread widening is<br />

the practice of artificially widening the bid/ask spread<br />

when accounts are in a profit, to eliminate said profit<br />

or even forcing accounts to incur a loss due to margin<br />

issues, says Richards.<br />

Ditlove says <strong>MB</strong> <strong>Trading</strong> holds its liquidity providers<br />

to fairly specific terms that if they are showing a price,<br />

they have to execute a certain amount at that price. He<br />

adds that obviously, there are scenarios such as news<br />

releases where more orders are being fired at them<br />

and they also want to execute less. But compared to<br />

years ago when a deal desk could slip a customer 100<br />

pips because of the non-farm payroll data releasing,<br />

things have come a long way, he claims, adding: “Does<br />

every fill occur on the visible bid and ask at the time<br />

you click the button? Probably not under fast market<br />

conditions, which is no different then an NYSE<br />

specialist who is charged with maintaining an orderly<br />

market.<br />

“That being said, the way to combat this circumstance<br />

is to add more liquidity venues to our system,” Ditlove<br />

continues. “<strong>MB</strong> <strong>Trading</strong> is an aggregator of liquidity;<br />

if we find that there is less then optimal liquidity we<br />

add more banks as sources. But that doesn’t change the<br />

fact that our routing algorithms are very fast and our<br />

liquidity provider relationships are fairly deep, so the<br />

system will generally find a way to get a fill in a timely<br />

manner. The main point that I would focus on is that<br />

any slippage that occurs on our system is a function<br />

of global supply and demand, as opposed to a DD<br />

that refuses to give a retail client a fair deal in order to<br />

maximise their own profit.”<br />

<strong>ECN</strong> settlement<br />

On how the FX <strong>ECN</strong> model works and how it<br />

operates on a settlement rather than pricing basis,<br />

Richards says because forex is a non-centralised<br />

market, there are two ways for retail traders to access<br />

it; either through a MM offering marked up liquidity<br />

from one or several liquidity providers, or through an<br />

<strong>ECN</strong>-style system.<br />

Jesse Richards<br />

“The two most common forms of manipulation traders<br />

complain about are stop hunting and spread widening.”<br />

“Now, it should be noted that while banks, prime<br />

brokers and large institutional traders may operate on<br />

a settlement basis utilising a true <strong>ECN</strong> environment,<br />

most retail forex <strong>ECN</strong> style accounts still operate on<br />

a pricing basis even if they are STP, NDD accounts,”<br />

Richards explains. “On a retail forex <strong>ECN</strong> style system,<br />

while it may operate on a STP basis, the counterparty<br />

to the client’s transaction is ultimately a prime broker,<br />

who is not aware of the identity of the client. Instead,<br />

the prime broker has a credit relationship only with the<br />

broker counterparty, that is, the company you would<br />

normally open an account and deposit your funds with.<br />

Retail <strong>ECN</strong> models eliminate the inherent conflict of<br />

interest that exists with a MM, but do not truly operate<br />

on a settlement basis.”<br />

Costs and fees to trade on <strong>ECN</strong>s depend on different<br />

factors, according to Zagara. Generally speaking, he<br />

says the trader is offered an ‘all inclusive’ commission<br />

quote which includes the broker’s profit and fees. The<br />

broker then pays its fees to the prime broker and to the<br />

<strong>ECN</strong> itself, which charge a transaction or clearing fees,<br />

similarly to futures exchanges. Some of these charges<br />

do not apply to what Zagara considers to be ‘home<br />

made’ <strong>ECN</strong>s. Also, he notes that while more brokers are<br />

embracing the forex <strong>ECN</strong> style, we can expect to see a<br />

growing commission battle among brokers, which will<br />

eventually benefit the traders; a similar path that the<br />

electronic futures have followed in the past.<br />

However, Kisyov adds it is the individual trading style<br />

that matters when choosing a trading model, in terms<br />

of the potential impact on trading performance.<br />

“It is always about costs involved and execution<br />

when elaborating on the choice of a<br />

trading model. With variable spreads,<br />

the difference between the bid and<br />

ask prices of a certain currency pair<br />

fluctuates in a range. On the other<br />

hand, fixed spreads are predetermined<br />

under all market conditions.”<br />

Kisyov states that Deltastock’s fixed spread on<br />

EUR/USD is 2 pips, while it goes down to 0.1 pips<br />

in the <strong>ECN</strong>/STP module. The company has utilised<br />

direct pricing with no mark-up or mark-down from<br />

its liquidity providers, and the only fee that applies for<br />

<strong>ECN</strong>-STP order execution is 0.3 pips for trades as low<br />

as 10,000 base currency units. So, assuming a EUR/<br />

USD order is executed at 0.1 pips spread, the bottom<br />

line for clients will be 0.4 pips total transaction costs.<br />

MT4 bridging issues<br />

Bringing <strong>ECN</strong> trading to the retail trader, many firms<br />

offering <strong>ECN</strong> trading now claim to bridge to the everpopular<br />

MT4 platforms. On issues with bridging an<br />

MT4 platform to an <strong>ECN</strong>, Ditlove says <strong>MB</strong> <strong>Trading</strong><br />

spent more than a year finding out. He states: “The<br />

short version is that MT4 is half a decade old at this<br />

point, and MetaQuotes is busy working on MT5<br />

now. When MT4 came around, there were no <strong>ECN</strong><br />

forex brokers. It’s a round plug in a square hole. We<br />

had to meticulously<br />

consider every part of<br />

how MT4’s architecture<br />

worked and strip out pieces<br />

that simply didn’t make sense<br />

in our current execution model.<br />

There are now a lot of brokers<br />

that claim to be FX <strong>ECN</strong>s with<br />

MT4, but we review what they are claiming and know<br />

that at best, they are simply routing orders out to one<br />

destination and again failing the transparency test.”<br />

Most of the issues are technology related, although<br />

the prime reason for there being issues is because<br />

FX <strong>ECN</strong>’s and MT4 have vastly different trading<br />

philosophies, says Vedikhin. The biggest challenge, he<br />

warns, is to be able to match client orders from MT4<br />

with liquidity from an <strong>ECN</strong>. <strong>ECN</strong>’s show market<br />

depth but MT4 does not, so it is important to resolve<br />

the issue of execution when an MT4 client wants a<br />

trade executed immediately at the best possible price.<br />

“In MT4 it is not possible to provide partial fills, but<br />

<strong>ECN</strong> platforms often execute client orders at slightly<br />

different prices subject to available liquidity at a<br />

particular price. This core difference in approach can<br />

cause issues when bridging liquidity,” he comments.<br />

Zagara says Fastbrokers.com explored MT4 bridging<br />

132 | april 2010 e-FOREX april 2010 e-FOREX | 133


RETAIL e-FX CLIENT<br />

in late 2007, when more clients started to demand a<br />

real <strong>ECN</strong> execution delivered on the MT4.<br />

Fastbrokers.com concluded that clean bridging seemed<br />

to work only in theory. Zagara says: “It is a very tough<br />

task to achieve in a live environment, mainly for the<br />

nature of the MT4 infrastructure, where its core, in<br />

my opinion, is mainly designed for a dealing desk<br />

usage only. Furthermore, each <strong>ECN</strong> has is own trading<br />

and order rules, different API specification and FIXcommunication<br />

issues. Our tests reported problems<br />

with split fills (which MT4 wasn’t able to handle), off<br />

quotes caused by latency (trades were passed while the<br />

price on the <strong>ECN</strong> had changed), which made possible<br />

the use of a bridge in a hybrid model but it was not<br />

possible to make it work in a true STP-only model.<br />

“For that purpose we dismissed the MT4-<strong>ECN</strong><br />

project and switched to focus our custom software<br />

to fill this gap,” explains Zagara. “I am sure now<br />

things have changed; there are different and more<br />

powerful bridges. However, in my opinion, I am still<br />

very sceptical when I see a broker claiming is offering<br />

an MT4 through an <strong>ECN</strong>. I would scrutinise both<br />

the bridge and whether the <strong>ECN</strong> it connects to was<br />

specifically designed or modified to handle MT4-like<br />

platforms, to the extent that the benefits of a regular<br />

<strong>ECN</strong> may have been compromised to accommodate<br />

the needs of MT4,” he warns.<br />

Ross Ditlove<br />

“There are now a lot of brokers that claim to be FX <strong>ECN</strong>s<br />

with MT4, but we review what they are claiming and know<br />

that at best, they are simply routing orders out to one<br />

destination and again failing the transparency test.”<br />

Richards adds: “There have been many challenges<br />

getting this marriage to work. As, in my opinion,<br />

the MT4 software was never really meant to execute<br />

through an <strong>ECN</strong>. Currenex, through its executable<br />

streaming prices model, is another company making<br />

headway in retail <strong>ECN</strong> trading. If a broker signs on<br />

with Currenex they will have true STP-NDD accounts<br />

available for their clients,” he claims.<br />

<strong>ECN</strong> or not <strong>ECN</strong>?<br />

On what factors may ultimately govern whether a trader<br />

should consider using a forex <strong>ECN</strong> platform or not,<br />

Zagara states that while some traders, when delivered a<br />

true <strong>ECN</strong> product, enjoy the liquidity and volatility of<br />

these feeds, they are sometimes quickly overwhelmed<br />

not only by the commission charges, lower leverage,<br />

and higher balance required, but especially with the less<br />

user friendly trading platforms that allow you to trade<br />

on it. Zagara comments: “That reason led us to develop<br />

Pathfinder Trader, which includes trading on different<br />

<strong>ECN</strong>’s but delivered on a front end with the most<br />

advanced features, such as, powerful charting, auto<br />

execution, back testing, pattern recognition, and any<br />

other advanced functionality you would expect from a<br />

modern trading platform.”<br />

Vedikhin comments: “At Alpari (UK) we believe that<br />

over 95% of forex retail trading will go through <strong>ECN</strong>’s<br />

within the next five years, but there are some obstacles<br />

in the way. The first is that <strong>ECN</strong> trading is often too<br />

expensive for the majority of retail traders. Account<br />

opening requirements are usually much steeper<br />

compared to traditional FX trading, while leverage<br />

is much lower. The other obstacle is complexity.<br />

<strong>ECN</strong>’s often come across as too complicated and<br />

‘institutional’ for retail traders. We believe that over<br />

time <strong>ECN</strong> trading will become progressively simpler<br />

as users become more informed and educated about<br />

its potential. Cost of entry and complexity are both<br />

obstacles that can be overcome.”<br />

While Ditlove notes: “We would obviously argue<br />

that not using a true <strong>ECN</strong> platform is at some point<br />

detrimental to the trader, but there are still people who<br />

view it differently. Our goal is to have a transparent<br />

display system that prohibits games, and for some<br />

people that have been around a while, the importance<br />

of that is lost. Can they make the argument that with<br />

a fixed spread, no-commission model it is easier to<br />

know what you’re getting? Maybe. Is it cost effective<br />

and better in the end? I would question whether that<br />

is the case. Simply stated, transparency in a market<br />

place brings efficiency and efficiency brings value.”<br />

134 | april 2010 e-FOREX

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