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Proposed NFA Capital Requirement

  • #401
  • Sep 28, 2007 4:10pm Sep 28, 2007 4:10pm
Quoting merlin
are you close to this situation? and if not, how could you possibly come to such a conclusion?
No, I'm not close to the situation. This is strictly my own personal opinion and maybe completely off My reasoning is that FXSol raised $100mm but their excess net capital only rose a couple of million to $15mm. On top of that, according to the NFA site the 2 founders who originally both had more than 10% of the firm's stock now both have less, which likely means that they sold their own personal share as part of this deal.

I don't think the whole $100mm went into anyones pockets, just some it.

Again, complete speculation on my part, but then this whole thread is a lot of speculation.
  • #402
  • Sep 28, 2007 4:19pm Sep 28, 2007 4:19pm
Quoting flyingduck
No, I'm not close to the situation. This is strictly my own personal opinion and maybe completely off My reasoning is that FXSol raised $100mm but their excess net capital only rose a couple of million to $15mm. On top of that, according to the NFA site the 2 founders who originally both had more than 10% of the firm's stock now both have less, which likely means that they sold their own personal share as part of this deal.
.
If the firm has issued new stock to raise capital, then the the original owners' share is diluted. I.e. if you own 10% of a 50mil company, you are worth 5mil. If you issue another 50mil worth of stock to outsiders, then you still have 5mil, but your ownership has dropped to 5%. Does your source state the actual value of their ownership, or just the percentage? Just curious....
  • #403
  • Edited 8:51pm Sep 28, 2007 4:24pm | Edited 8:51pm
forexsaviour - thx for keeping this up to date, and also thanks to you & the other main participants for bringing the debate to a civil level. It is really quite an eye-opener...As for the excess capital, thinking about this last night I realized that if FXCM (just to use them as an example) has around 100K customers, then 50mil is only about 500$ per customer. It's actually not a lot in a turbulent market, is it...

(added later) sorry, I've got 50mil on the brain...the proposed 20mil requirement is only 200$/customer for a firm like FXCM. I wonder why they don't just set it to something like the Fed M1 account requirement (10%)...
  • #404
  • Sep 28, 2007 5:55pm Sep 28, 2007 5:55pm
Thank you Forexsavior. Valuable info indeed!
  • #405
  • Sep 28, 2007 11:12pm Sep 28, 2007 11:12pm
[quote=forexsavior;1617975]Only days after the President of the NFA told the Congress he wanted them to raise the minimum capital requirement to $20 million the CFTC signed off on the NFA's current capital requirement increase to $5 million. And they are not waiting around till 2008. Firms need to have the money in the bank by DECEMBER. That's right around the corner.

With the forex industry rapidly changing before our very eyes I wanted to put together a much more comprehensive list of the industry's financial status. Therefore, I have included every single registered Forex Dealer member and listed their Adjusted Net Capital. Since I first started posting about the NFA proposal over a dozen firms have gone out of business. Two others have merged and several others are staring death in the face. It is astonishing that firms like Hamilton Williams (Velocity FX) can operate only $4,000 above the minimum needed to stay in business. How on earth can such a firm survive a few months from now when they're practically pushing up the daisies already? Here is the direct link for the CFTC capital reports: http://www.cftc.gov/marketreports/financialdataforfcms/

Firms Under $5 Million
All these firms are reporting adjusted net capital below the $5 million mark as of the latest CFTC report. Some should be able to raise the necessary capital. Others clearly will not. Which ones can and can't will be anybody's guess. Already one of these firms, One World Capital, is not allowing customers to withdraw money.

Hamilton Williams ($1,004,000)
IG Financial Markets ($1,010,000)
Advanced Markets ($1,042,000)
One World Capital ($1,078,000)
Direct Forex ($1,117,000)
SNC Investments ($1,130,000)
Wall Street Derivatives ($1,220,000)
I Trade FX LLC ($1,801,000)
Solid Gold Financial ($1,955,000)
CMC Markets ($2,330,000)
MB Trading ($2,393,000)
GFS Futures & Forex ($3,259,000)
E FX Options ($3,342,000)
Forex Club ($3,715,000)
Easy Forex ($4,731,000)

Firms Under $20 Million
These firms all meet the coming minimum adjusted net capital requirement. However, there are other capital requirements that as market makers these firms (HotSpot excepted in some cases) will need to meet in addition to the minimum $5 million. Most firms will likely need $10 million to be in compliance with the NFA's rules. Clearly firms like Money Garden are not in the clear just yet.

Money Garden ($5,162,000)
HotSpot FX ($5,990,000)
IKon ($7,130,000)
ODL Securities ($10,822,000)
CMS Forex ($11,849,000)
IFX Markets ($12,293,000)
PFG Forex ($12,781,000)
FX Solutions ($15,077,000)

Firms Over $20 Million
These are the most well capitalized firms in the industry and two years from now may very well be the only firms left in the industry if Dan Roth and the NFA have their way and increase cap requirements to $20 million.

Interbank FX ($25,178,000)
Gain Capital (29,061,000)
Forex Liquidity ($39,909,000)
FXCM ($50,465,000)
Oanda ($50,837,000)
GFT Forex ($54,662,000)

Firms No Longer in Business
These are the firms that have gone out of business since I began posting on the forum. That's a quarter of the industry in just a few months. And one of those firms, Nations LLC, has gone into bankruptcy and customers can't get their money back, and may never get their money back.

Bacera Corporation
Cal Financial Corporation
FiniFX
Forward Forex
FX Option1 Inc.
Nations Investments
Performance Capital International
Spencer Financial
Tradex Swiss AG
Trend Commodities
United Global Markets
Worldwide Clearing

Firms that Merged
These are the firms that could not make the new capital requirement on their own and decided to merge with larger players as a result.

American National Trading Corp (Merged with PFG)
Royal Forex Trading (Merging with IKON)

Summary
It is a very turbulenet time in the forex industry. My advice is what it has always been, do not trade with a poorly capitalized firm. And if you must, at least wait until after the December 17, 2007, deadline before putting any money on deposit with any firm that is not meeting the current minimum capital requirement.[/quote

I am thinking of opening an account with PFG. It would be a managed account with a trader that I like. Either I have this choice or have to consider a swiss broker.
What do you think?
Thanks
M
  • #406
  • Sep 30, 2007 10:28am Sep 30, 2007 10:28am
thanks for the post, although i don't agree with your point about firms under 20million.
first, those firms that have ability to maintain the capital requirement show their determination and capacity to continue business.
second, those firms with clean records and strong internal control system would attract more investors.

Quoting forexsavior
Only days after the President of the NFA told the Congress he wanted them to raise the minimum capital requirement to $20 million the CFTC signed off on the NFA's current capital requirement increase to $5 million. And they are not waiting around till 2008. Firms need to have the money in the bank by DECEMBER. That's right around the corner.

With the forex industry rapidly changing before our very eyes I wanted to put together a much more comprehensive list of the industry's financial status. Therefore, I have included every single registered Forex Dealer member and listed their Adjusted Net Capital. Since I first started posting about the NFA proposal over a dozen firms have gone out of business. Two others have merged and several others are staring death in the face. It is astonishing that firms like Hamilton Williams (Velocity FX) can operate only $4,000 above the minimum needed to stay in business. How on earth can such a firm survive a few months from now when they're practically pushing up the daisies already? Here is the direct link for the CFTC capital reports: http://www.cftc.gov/marketreports/financialdataforfcms/

Firms Under $5 Million
All these firms are reporting adjusted net capital below the $5 million mark as of the latest CFTC report. Some should be able to raise the necessary capital. Others clearly will not. Which ones can and can't will be anybody's guess. Already one of these firms, One World Capital, is not allowing customers to withdraw money.

Hamilton Williams ($1,004,000)
IG Financial Markets ($1,010,000)
Advanced Markets ($1,042,000)
One World Capital ($1,078,000)
Direct Forex ($1,117,000)
SNC Investments ($1,130,000)
Wall Street Derivatives ($1,220,000)
I Trade FX LLC ($1,801,000)
Solid Gold Financial ($1,955,000)
CMC Markets ($2,330,000)
MB Trading ($2,393,000)
GFS Futures & Forex ($3,259,000)
E FX Options ($3,342,000)
Forex Club ($3,715,000)
Easy Forex ($4,731,000)

Firms Under $20 Million
These firms all meet the coming minimum adjusted net capital requirement. However, there are other capital requirements that as market makers these firms (HotSpot excepted in some cases) will need to meet in addition to the minimum $5 million. Most firms will likely need $10 million to be in compliance with the NFA's rules. Clearly firms like Money Garden are not in the clear just yet.

Money Garden ($5,162,000)
HotSpot FX ($5,990,000)
IKon ($7,130,000)
ODL Securities ($10,822,000)
CMS Forex ($11,849,000)
IFX Markets ($12,293,000)
PFG Forex ($12,781,000)
FX Solutions ($15,077,000)

Firms Over $20 Million
These are the most well capitalized firms in the industry and two years from now may very well be the only firms left in the industry if Dan Roth and the NFA have their way and increase cap requirements to $20 million.

Interbank FX ($25,178,000)
Gain Capital (29,061,000)
Forex Liquidity ($39,909,000)
FXCM ($50,465,000)
Oanda ($50,837,000)
GFT Forex ($54,662,000)

Firms No Longer in Business
These are the firms that have gone out of business since I began posting on the forum. That's a quarter of the industry in just a few months. And one of those firms, Nations LLC, has gone into bankruptcy and customers can't get their money back, and may never get their money back.

Bacera Corporation
Cal Financial Corporation
FiniFX
Forward Forex
FX Option1 Inc.
Nations Investments
Performance Capital International
Spencer Financial
Tradex Swiss AG
Trend Commodities
United Global Markets
Worldwide Clearing

Firms that Merged
These are the firms that could not make the new capital requirement on their own and decided to merge with larger players as a result.

American National Trading Corp (Merged with PFG)
Royal Forex Trading (Merging with IKON)

Summary
It is a very turbulenet time in the forex industry. My advice is what it has always been, do not trade with a poorly capitalized firm. And if you must, at least wait until after the December 17, 2007, deadline before putting any money on deposit with any firm that is not meeting the current minimum capital requirement.
  • #407
  • Sep 30, 2007 10:32am Sep 30, 2007 10:32am
That is why I don't like those big firms too. There are too many tricks in firms like fxcm and forex. I believe a lot of people have already realized it.
I'd rather trade with a mid sized firm.

.
Quoting F-100
NFA must investigate, I have a challange for NFA, Good to write these things to your senator.Just let them know about forex Fraud.
some of the brokers including FOREX.COM , FXCM are tricky, Forex.com make money on swap you can not find out daya to day basis.
  • #408
  • Oct 1, 2007 10:16am Oct 1, 2007 10:16am
[quote=mahvashd;1618623]
Quoting forexsavior
Only days after the President of the NFA told the Congress he wanted them to raise the minimum capital requirement to $20 million the CFTC signed off on the NFA's current capital requirement increase to $5 million. And they are not waiting around till 2008. Firms need to have the money in the bank by DECEMBER. That's right around the corner.

With the forex industry rapidly changing before our very eyes I wanted to put together a much more comprehensive list of the industry's financial status. Therefore, I have included every single registered Forex Dealer member and listed their Adjusted Net Capital. Since I first started posting about the NFA proposal over a dozen firms have gone out of business. Two others have merged and several others are staring death in the face. It is astonishing that firms like Hamilton Williams (Velocity FX) can operate only $4,000 above the minimum needed to stay in business. How on earth can such a firm survive a few months from now when they're practically pushing up the daisies already? Here is the direct link for the CFTC capital reports: http://www.cftc.gov/marketreports/financialdataforfcms/

Firms Under $5 Million
All these firms are reporting adjusted net capital below the $5 million mark as of the latest CFTC report. Some should be able to raise the necessary capital. Others clearly will not. Which ones can and can't will be anybody's guess. Already one of these firms, One World Capital, is not allowing customers to withdraw money.

Hamilton Williams ($1,004,000)
IG Financial Markets ($1,010,000)
Advanced Markets ($1,042,000)
One World Capital ($1,078,000)
Direct Forex ($1,117,000)
SNC Investments ($1,130,000)
Wall Street Derivatives ($1,220,000)
I Trade FX LLC ($1,801,000)
Solid Gold Financial ($1,955,000)
CMC Markets ($2,330,000)
MB Trading ($2,393,000)
GFS Futures & Forex ($3,259,000)
E FX Options ($3,342,000)
Forex Club ($3,715,000)
Easy Forex ($4,731,000)

Firms Under $20 Million
These firms all meet the coming minimum adjusted net capital requirement. However, there are other capital requirements that as market makers these firms (HotSpot excepted in some cases) will need to meet in addition to the minimum $5 million. Most firms will likely need $10 million to be in compliance with the NFA's rules. Clearly firms like Money Garden are not in the clear just yet.

Money Garden ($5,162,000)
HotSpot FX ($5,990,000)
IKon ($7,130,000)
ODL Securities ($10,822,000)
CMS Forex ($11,849,000)
IFX Markets ($12,293,000)
PFG Forex ($12,781,000)
FX Solutions ($15,077,000)

Firms Over $20 Million
These are the most well capitalized firms in the industry and two years from now may very well be the only firms left in the industry if Dan Roth and the NFA have their way and increase cap requirements to $20 million.

Interbank FX ($25,178,000)
Gain Capital (29,061,000)
Forex Liquidity ($39,909,000)
FXCM ($50,465,000)
Oanda ($50,837,000)
GFT Forex ($54,662,000)

Firms No Longer in Business
These are the firms that have gone out of business since I began posting on the forum. That's a quarter of the industry in just a few months. And one of those firms, Nations LLC, has gone into bankruptcy and customers can't get their money back, and may never get their money back.

Bacera Corporation
Cal Financial Corporation
FiniFX
Forward Forex
FX Option1 Inc.
Nations Investments
Performance Capital International
Spencer Financial
Tradex Swiss AG
Trend Commodities
United Global Markets
Worldwide Clearing

Firms that Merged
These are the firms that could not make the new capital requirement on their own and decided to merge with larger players as a result.

American National Trading Corp (Merged with PFG)
Royal Forex Trading (Merging with IKON)

Summary
It is a very turbulenet time in the forex industry. My advice is what it has always been, do not trade with a poorly capitalized firm. And if you must, at least wait until after the December 17, 2007, deadline before putting any money on deposit with any firm that is not meeting the current minimum capital requirement.

Hugh you bring up a good point regarding medium sized firms. The medium sized firms on this list should be ok so long as they have over $10 million. I don't expect the NFA's $20 million proposal to get through in the immediate future. But the fact they are pushing so hard to eliminate smaller firms from the industry is a strong indication that they have no confidence in these firms. Again, I say if Regulators have no confidence in small firms neither should the trading public.
  • #409
  • Oct 2, 2007 1:44pm Oct 2, 2007 1:44pm
It is also worth pointing out that some "medium sized firms" can be quite larger than what their net capital happens to be (site the financial backing of firms like Hotspot and IFX Markets specifically)

Net Capital is important to look at but it doesn't always tell the full story.


[quote=forexsavior;1621311]
Quoting mahvashd


Hugh you bring up a good point regarding medium sized firms. The medium sized firms on this list should be ok so long as they have over $10 million. I don't expect the NFA's $20 million proposal to get through in the immediate future. But the fact they are pushing so hard to eliminate smaller firms from the industry is a strong indication that they have no confidence in these firms. Again, I say if Regulators have no confidence in small firms neither should the trading public.
  • #410
  • Oct 3, 2007 11:24am Oct 3, 2007 11:24am
Quote
t is also worth pointing out that some "medium sized firms" can be quite larger than what their net capital happens to be (site the financial backing of firms like Hotspot and IFX Markets specifically)

Net Capital is important to look at but it doesn't always tell the full story.

That's true Forex Sean. Which is why medium sized firms should be ok. Although Money Garden isn't quite yet out of the woods.
  • #411
  • Edited 4:15am Oct 4, 2007 4:01am | Edited 4:15am
Quoting forexsavior
I
Originally Posted by minter
I requested info regarding a FX Brokerage firm in SWITZERLAND.

The first reply is from SBFC (Swiss Federal Banking Commission) and the second reply is from MLCA (Money Laundering Controlling Authority) .I personally do not feel the SWISS regulators are not as proactive as the US side .What about UK 's FSA ? I will try to find out .

Dear Sir ,

For the time being, financial intermediaries providing foreign exchange trading are not subject to licensing by the SFBC, provided that they exclusively deal in foreign exchange on the spot market. It is however intended to amend the law to the effect that foreign exchange trading becomes a privilege of authorised banks.
( Not subjected to licensing by the SFBC - does not mean that they are not controlled/regulated. Tradex and Finex are currently under SFBC investigation. What do you call that?? I have asked the SFBC about your letter. They answered that they replied a general question with a general answer. They are not the body that is giving the licence. They confirmed the official authorities, in the Dukascopy thread that I mentioned. )
Foreign Exchange dealers fall under the scope of the Anti-Money Laundering Act (AMLA). As such, they may be subject - unless they are a member of a recognised self regulatory body - to direct supervision by the AML Control Authority (Anti-Money Laundering Control Authority AMLCA) at the Swiss Federal Finance Administration, Christoffelgasse 5, 3003 Berne, phone +41 31 323 39 94, fax +41 31 323 52 61, www.gwg.admin.ch/e/index.htm. You may check this authority concerning forex brokers in Switzerland.

We hope that we were able to help you further.

Yours sincerely


Secretariat of the
SWISS FEDERAL BANKING COMMISSION


sig. Christina Bürgi sig. Simone Flach
Communication&Media Communication&Media

Schwanengasse 12
P.O. Box
CH-3001 Berne
Phone +41 31 322 60 69
Fax +41 31 322 69 26
mailto:[email protected]
http://www.ebk.admin.ch




CH-3003 Bern, FFA, AMLCA, bdu
By email

[color=#493007][email protected][/color]

Sir ,
Our reference: 10-9/VER2007/wj

Bern, 31 August 2007

Re: List of regulated forex brokers in Switzerland

Dear Sir,

We acknowledge receipt of your inquiry of 30 August 2007 and have to inform you that we cannot supply you with the requested list. Forex companies are not under prudential supervision. No security for deposited funds is therefore given and no supervision of the quality of the services provided takes place.

Yours faithfully,

Anti-Money Laundering Control Authority
Brigitte Dumont Judith Wyss
Adm. Assistant Adm. assistant

The ( AMLCA ) Anti Money Laundering Control Authority over stepped their scope of Authority. In Switzerland, departments should occupy only what they are meant for. The AMLCA is now been refused the rights to show the contents of other governing bodies. Read their website.

Does the CFTC or NFA check the books of the brokers every few months??????? I doubt. Likewise, in Switzerland, controls will be caried out only when someone files a complaint.
Please check that. I have seen the interpretation of that letter turned into the Swiss having a wild wild west Financiai system. Switzerland is a small country. If Switzerland must copy the US style of having so many departments of administration, the whole population can work as government servants and live only on the state.
  • #412
  • Oct 4, 2007 10:29am Oct 4, 2007 10:29am
Highway Swiss firms ARE NOT REGULATED. Enough already. Why do you keep trying to pretend otherwise? The Swiss fx market is a complete shambles with two swiss firms, Tradex Swiss AG and Finex halting customer withdrawals and the trading public being completely abandoned by non-responsive government agencies.

Trading with a Swiss Firm is too risky. Customers should avoid firms like Dukas and ACM until they actually bother to get a trading license, WHICH THEY DO NOT HAVE.
  • #413
  • Oct 4, 2007 11:41am Oct 4, 2007 11:41am
Two of the biggest FX Brokers are preparing for the coming increase in capital requirements by loading up their balance sheets.

First, Oanda has landed $100 million in funding:
http://www.americanventuremagazine.c...hp?newsid=3474

Quote
Online currencies information and trading system Oanda Corp has received a $100 million investment from a consortium of firms, the company announced Monday. The consortium is led by New Enterprise Associates and includes Legg Mason (LM), Cascade Investment LLC and T. Rowe Price Group Inc. (TROW). The proportion that each firm is contributing to the investment wasn't disclosed.

Michael Stumm, co-founder of Oanda, told Dow Jones Newswires that the investment wasn't aimed at financing any particular projects. "It's primarily to beef up our balance sheet," he said. "We're a market maker and we're in the financial services industry so the balance sheet plays an important role."

Meanwhile, FXCM has released its own balance sheet to the general public:
http://www.fxstreet.com/forum/showth...=6933#post6933

Quote
Balance Sheet (Unaudited)
AS OF AUGUST 31, 2007
CUSTOMER CASH 296,474,636
OPERATING CASH 96,311,380
OTHER ASSETS 19,666,212
FIXED ASSETS 9,821,211
TOTAL ASSETS 422,273,439
CUSTOMER DEPOSITS 296,474,636
OTHER LIABILITIES 5,662,597
TOTAL LIABILITIES 302,137,233
FXCM CAPITAL 120,136,206
TOTAL LIABILITIES AND FXCM CAPITAL 422,273,439

Drew Niv, CEO of the trading firm, commented: “FXCM is proud of our continued financial discipline and strong balance sheet. We believe clients should have the necessary information to make intelligent choices.”

FXCM also commented on the proposed increase in capital requirements and stated:

Quote
Although this new $5 million capital requirement has yet to take affect, NFA’s president and Chief Executive Officer has already testified before congress that capital levels for Forex Dealer Members should be raised to $20 million.
Forex Capital Markets, LLC, an NFA member firm, is the US regulated entity of the FXCM Group. As of August 31, 2007 Forex Capital Markets, LLC had an adjusted net capital of $60,268,390.
According to Niv, “The financial resources for FXCM (Forex Capital Markets, LLC) far exceed both the recently announced increased $5 million capital requirement level as well as the $20 million capital level proposed by NFA’s president and CEO in his recent congressional testimony.”

So what are the smaller firms waiting for? Why haven't we been hearing these kinds of reassuring statements from the poorly capitalized firms under $5 million? Are they going to be able to meet the coming $5 million capital requirement due in just two months? Why aren't these firms releasing their own balance sheets? Many of the firms under $5 million claim to have additional resources they are not reporting. So why don't they tell us about these "unreported assets." The silence from the sub-$5 million fx brokers is deafening. And it should be a warning sign for traders to beware doing business with them until it becomes clear that they actually have a future.
  • #414
  • Oct 4, 2007 11:44am Oct 4, 2007 11:44am
How secure will peoples funds be if the brokers arn't able to meet the deadline? Personally I have an account with CMS forex.. All my other accounts are with UK Brokers.
  • #415
  • Oct 4, 2007 12:09pm Oct 4, 2007 12:09pm
Quoting peterM
How secure will peoples funds be if the brokers arn't able to meet the deadline? Personally I have an account with CMS forex.. All my other accounts are with UK Brokers.
Well CMS has more than enough money to meet the current capital requirement. It is these firms that are currently below $5 million:

Firms Under $5 Million
All these firms are reporting adjusted net capital below the $5 million mark as of the latest CFTC report. Some should be able to raise the necessary capital. Others clearly will not. Which ones can and can't will be anybody's guess. Already one of these firms, One World Capital, is not allowing customers to withdraw money.

Hamilton Williams ($1,004,000)
IG Financial Markets ($1,010,000)
Advanced Markets ($1,042,000)
One World Capital ($1,078,000)
Direct Forex ($1,117,000)
SNC Investments ($1,130,000)
Wall Street Derivatives ($1,220,000)
I Trade FX LLC ($1,801,000)
Solid Gold Financial ($1,955,000)
CMC Markets ($2,330,000)
MB Trading ($2,393,000)
GFS Futures & Forex ($3,259,000)
E FX Options ($3,342,000)
Forex Club ($3,715,000)
Easy Forex ($4,731,000)
  • #416
  • Oct 5, 2007 12:47am Oct 5, 2007 12:47am
Have there been any statements from the firms under 5m since the approval and date set for the increase? If you are informing us on this subject, I'd appreciate any statements from any of the brokers currently under the 5mil as they are made. Thanks much.
  • #417
  • Oct 5, 2007 2:22am Oct 5, 2007 2:22am
I have account at One World Capital, more than 40 days cant get out my money till now !
Charting Markets into the Future...MǎҖ€¥.
  • #418
  • Oct 5, 2007 2:58am Oct 5, 2007 2:58am
Quoting MaXeY
I have account at One World Capital, more than 40 days cant get out my money till now !
They letting you get it though?
  • #419
  • Oct 5, 2007 3:53am Oct 5, 2007 3:53am
Till this moment i got nothing at all, even we complain to NFA but they did nothing.

so seems NFA uselss !

Quoting Pip Hunter E
They letting you get it though?
Charting Markets into the Future...MǎҖ€¥.
  • #420
  • Oct 5, 2007 6:16am Oct 5, 2007 6:16am
Sorry to hear that.

I'm actually sitting on most of my trading capital because I really need to see how this all shakes out before I send it to a firm that might be closed Dec 18th. (Which is fine for now, still live-trading small while I refine my methods).
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