Should You Consider Using A Forex ECN Platform? - MB Trading
Should You Consider Using A Forex ECN Platform? - MB Trading
Should You Consider Using A Forex ECN Platform? - MB Trading
You also want an ePaper? Increase the reach of your titles
YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.
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 />
126 | april 2010 e-FOREX
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 />
128 | april 2010 e-FOREX
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 />
130 | april 2010 e-FOREX
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