Saturday, 21 July 2018

Raft cut loose: HF tower for HFT refused

Sniper's Tweet (click to enlarge)
Alexandre Laumonier, aka @SniperInMahwah, noted via tweet an HF and microwave tower for HFT application has been refused in the UK by a parish council.

In the application from Doron Bar of Raft Technologies, from a popular address in Israel, Raft wanted to put a fairly modest tower for HF with microwave links "near the settlement of Taplow, close by Maidenhead in Berkshire but within the administrative area of South Bucks District Council."

Tower site near Taplow (click to enlarge)
Approximate coordinates: 51°31'26.6"N 0°41'18.7"W (51.524065, -0.688536).
(click to enlarge)

(click to enlarge)
Note to self: if you are going to put in a disguised tower, at least use a picture of a disguised tower to improve your chances. Putting a picture of a tower that proudly stands out in the skyline may not be the best way to convey discretion for a Green Belt. Whilst it is a great picture of such a tower, I couldn't imagine a worse picture for a council application. The picture looks much more imposing than it actually would be. Oops.

Source (click to enlarge)

Alexandre has some interesting details yet to come on the HF comings and goings on his side of the pond. Worth waiting for...

Happy trading,


Tuesday, 17 July 2018

Mr Bob Van Valzah on "Why your transatlantic trades are getting picked off"

Mr Bob Van Valzah spoke at STAC on HF for HFT at STAC in New York on 13th of June.

Here is STAC's page, with the link to the video of the presentation: "Why your transatlantic trades are getting picked off."

The slides are available at that web, or directly here.

Thanks Bob for the shout out to "Lines, radios, and cables - oh my."

Happy trading,


Monday, 16 July 2018

US Finra ATS Tier 1 statistics released 16-July-2018 for 25-June-2018 ATS

EBXL Level ATS levels up two levels. The tussle from third to sixth remains tight.

ATS share
click to enlarge

# ATS T1 share % Qty Trades Avg trade size Δ
1 UBSA UBS ATS 18.51 521.2 M 3,431,533 152
2 CROS CROSSFINDER 10.21 287.6 M 1,856,190 155
3 MSPL MS POOL (ATS-4) 7.04 198.3 M 848,206 234
4 EBXL LEVEL ATS 6.79 191.3 M 967,859 198 +2
5 JPMX JPM-X 6.61 186.2 M 947,457 196 -1
6 DBAX SUPERX 6.42 180.9 M 924,705 196 -1
7 LATS BARCLAYS ATS (“LX”) 6.33 178.2 M 930,130 192
8 SGMT SIGMA X2 5.52 155.4 M 967,646 161
9 BIDS BIDS TRADING 5.07 142.7 M 105,619 1,351
10 MLIX INSTINCT X 3.28 92.2 M 429,612 215
11 ITGP POSIT 3.06 86.1 M 257,815 334
13 MSTX MS TRAJECTORY CROSS (ATS-1) 2.13 59.9 M 362,201 165
14 KCGM VIRTU MATCHIT 1.97 55.6 M 325,149 171
15 DLTA DEALERWEB 1.90 53.4 M 197 271,178
16 LQNA LIQUIDNET H2O 1.63 45.8 M 2,135 21,459
17 JPBX JPB-X 1.49 42.1 M 301,343 140
18 IATS IBKR ATS 1.38 38.7 M 148,894 260
19 BLKX BLOCKCROSS 1.32 37.1 M 2,999 12,386
20 CXCX CITI CROSS 1.14 32.2 M 154,611 208 +1
21 XSTM CROSSSTREAM 1.09 30.6 M 90,006 340 -1
22 LQNT LIQUIDNET ATS 1.08 30.5 M 787 38,728 +1
23 LMNX LUMINEX TRADING & ANALYTICS LLC 0.85 23.9 M 574 41,595 -1
24 MSRP MS RPOOL (ATS-6) 0.78 21.9 M 124,404 176 +1
25 PDQX CODA MARKETS, INC. 0.55 15.4 M 70,695 218 +1
26 XIST INSTINET CROSSING 0.38 10.6 M 3,300 3,208 -2
27 CBLC CITIBLOC 0.31 8.8 M 532 16,606
28 CIOI CIOI 0.22 6.2 M 87 71,238
29 AQUA AQUA SECURITIES L.P. 0.06 1.6 M 195 8,179
30 WDNX XE 0.04 1.0 M 961 1,066
31 PROS PRO SECURITIES ATS 0.01 0.2 M 441 535
33 MAGM MAGMA ATS 0.00 0.0 M 28 650

ATS share
click to enlarge

ATS share
click to enlarge

Saturday, 14 July 2018

Crypto crime - a recycled vignette

The US filed against the Russian hackers today. The ever-vigilant Mr Kipp Rogers tweeted these wise words:
Twitterish linkage of sorts
(click to enlarge)
I remain convinced crypto-crime is the most likely threat to the longevity of various coins, including $BTC. Though crime is more of a problem with the coinage designed for completely anonymous transactions such as Monero, Dash, Zcash, etcetera.

Here is a forte reverberation of something I wrote a few months ago, previously buried in the mix of the article, "The market factory: things that make you go hmmm."

It seems a little more relevant today after the DoJ's filing.


Crypto-currency crime
February 2018

Bubbles come and go. Meh. Being libertine at heart -  even though the libertine part seems to be shrinking with age - I'm disturbed by my disturbance at the marketing around so-called virtual currencies. Octogenarian family friends, who can't use an iPad, make enquiries about BitCoin. I suspect you, as a knowledgeable technology or finance peep, have been asked similar questions even if you are no longer reading this all too long meander.

If you are no longer reading I presume you will still know if you've been asked about such coinage - despite the breaking of the fourth wall. It is a worry the National TV News from the public broadcaster here has had BitCoin prices and commentary in the nightly finance report for many months. Crazy stuff for something with the mirage of the modest market cap of a single stock. When remote Tasmanian retail, or the shoe-shiner, asks about Bitcoin, you know you have a retail problem that needs some unfortunate regulatory consideration.

I wrote a child-like meander about crypto-currency and crime last week, "Your crypto-currency response will be weighed." It serves little purpose other than as therapy but I enjoyed the music. The important aspect is to realise, according to the UN, there are some 40,000,000 modern slaves in the world and they deserve their AML back. There are kids being abused and photographed with their pictures being hosted on servers paid for with BitCoin.

Yep, slavery is still a thing:

My musing meandered me to the point of view that crime may destroy BitCoin before other factors, say bubbles. The regulators have been asleep at the wheel. Perhaps with its minor transaction flow profile virtual currencies didn't deserve too much attention, but the genie escaped that bottle years ago. The regulators could have nipped this nightmare in the bud with some pretty simple regulations. They failed in their mission.

Most disagreed with this point of view in comments sent back, though I appreciated some support. I'm hoping this is another Søren Kierkegaard moment where my minority view may be right.

Society has a point. There is a minor fraction of real currency that is laundered. There is a minority, estimated to be a much bigger minority, of virtual currency that is likewise laundered. For the non-virtual case, we've developed some pretty flawed regulations and laws in a ham-fisted attempt to stem such criminal activities. They have a point as the best we can do for now. The same regulations should be equally applied to virtual currencies.

Money laundering is a pretty big deal:

(Sourced from PWC - click to enlarge)

unless you think $2 trillion a year is nothing to worry about.

I've been especially critical of the CFTC's and SEC's tepid response. That seems to be changing as they ramp up their rhetoric to counter their embarrassing lack of action. See this sensible Written Testimony from the last week by Chairman J. Christopher Giancarlo. There is a lot of good work in there, including this piece on virtual currencies,
Let’s turn to virtual currencies. Emerging financial technologies are taking us into a new chapter of economic history. They are impacting trading, markets and the entire financial landscape with far ranging implications for capital formation and risk transfer. These emerging technologies include machine learning and artificial intelligence, algorithm-based trading, data analytics, “smart” contracts, and distributed ledger technologies. Over time, these technologies may come to challenge traditional market infrastructure. They are transforming the world around us, and it is no surprise that these technologies are having an equally transformative impact on U.S. capital and derivatives markets.
Supporters of virtual currencies see a technological solution to the age-old “double spend” problem – that has always driven the need for a trusted, central authority to ensure that an entity is capable of, and does, engage in a valid transaction. Traditionally, there has been a need for a trusted intermediary – for example a bank or other financial institution – to serve as a gatekeeper for transactions and many economic activities. Virtual currencies seek to replace the need for a central authority or intermediary with a decentralized, rules-based and open consensus mechanism. An array of thoughtful business, technology, academic, and policy leaders have extrapolated some of the possible impacts that derive from such an innovation, including how market participants conduct transactions, transfer ownership, and power peer-to-peer applications and economic systems.
Others, however, argue that this is all hype or technological alchemy and that the current interest in virtual currencies is overblown and resembles wishful thinking, a fever, even a mania. They have declared the 2017 heightened valuation of Bitcoin to be a bubble similar to the famous “Tulip Bubble” of the seventeenth century. They say that virtual currencies perform no socially useful function and, worse, can be used to evade laws or support illicit activity. Indeed, history has demonstrated to us time-and-again that bad actors will try to invoke the concept of innovation in order to perpetrate age-old fraudulent schemes on the public. Accordingly, some assert that virtual currencies should be banned, as some nations have done.
There is clearly no shortage of opinions on virtual currencies such as Bitcoin. In fact, virtual currencies may be all things to all people: for some, potential riches, the next big thing, a technological revolution, and an exorable value proposition; for others, a fraud, a new form of temptation and allure, and a way to separate the unsuspecting from their money. 
Perspective is critically important. As of the morning of February 12, the total value of all outstanding Bitcoin was about $149 billion based on a Bitcoin price of $8,800. The Bitcoin “market capitalization” is less than the stock market capitalization of a single “large cap” business, such as Disney around $156 billion. The total value of all outstanding virtual currencies was about $430 billion. Because virtual currencies like Bitcoin are sometimes considered to be comparable to gold as an investment vehicle, it is important to recognize that the total value of all the gold in the world is estimated by the World Gold Council to be about $8 trillion, which continues to dwarf the virtual currency market size. Clearly, the column inches of press attention to virtual currency far surpass its size and magnitude in today’s global economy. 
Yet, despite being a relatively small asset class, virtual currency presents complex challenges for regulators. Chairman Jay Clayton of the U.S. Securities and Exchange Commission (SEC) and I recently wrote: 
The CFTC and SEC, along with other federal and state regulators and criminal authorities, will continue to work together to bring transparency and integrity to these markets and, importantly, to deter and prosecute fraud and abuse. These markets are new, evolving and international. As such they require us to be nimble and forward-looking; coordinated with our state, federal and international colleagues; and engaged with important stakeholders, including Congress.
 It is this perspective that has guided our work at the CFTC on virtual currencies. Our work has six broad elements: (1) staff competency; (2) consumer education; (3) interagency cooperation; (4) exercise of authority; (5) strong enforcement; and, (6) heightened review of virtual currency product self-certifications.
The interagency mess is quite troubling. Self-certification is also troubling in this domain. We have the various SROs, SEC, CFTC, FinCEN, FBI, DOJ, FSOC, FSB, IOSCO all with a stake.

We have to be careful with our technology and regulations. Just because cameras are used for kiddie porn, we don't ban cameras. Similarly, mathematical truths and cryptography are too important for the good of humanity to limit or ban. The FBI and NSA are not too happy with solid cryptography being used in the wild. Shame on them. As a society, we have chosen another path. We choose to use society's lubricant, money, as one of the primary mechanisms to keep our children safe and to act against slavery. This, to me, remains a valid choice. Virtual currencies are subverting this due to a lack of oversight.

The docile and inactive FinCEN at least prosecuted the $4B laundry-o-mat that was BTC-e. A $110M fine was levied. Part of the case included highlighting not only the problem of bitcoin mixers but the clear and present danger of newer virtual currencies that provide untraceable features. Dash in this case:

With many next-generation coins, such as Zcash, and then Monero, improving on the usefulness of virtual currencies for crime, we need to wake up and process this nightmare that refuses to sleep. It is not possible for me to accept that Monero should be available for any reasonable transaction size given the impossibility of AML/KYC application to such a beast.

Australia introduced new virtual currency laws recently but a punter can still buy Monero at exchanges touting AML compliance. Many buy BTC at Coinbase and then convert to Monero.  It would seem there needs to be a central body or regulation that has viral properties. You can't expect global rules to be negotiated or exist - certainly not in a timely manner. A viral approach where you can't transact with a non-member or a non-compliant body is the only workable solution. A cabal of countries agreeing would be better, but the US or the EU could go it alone if necessary, again.

A further step would be for compliant venues to raise a Suspicious Transaction Report requirement for coinage going to non-compliant venues or being tumbled. It is right there in the chain and popular addresses are known or derivable. That is somewhat better than cash in that you can track the trackable, but not the new generation of crime-based coinage such as Monero. The viral possibilities in such an approach are better than what we have with cash. There is hope.

It does make you wonder if there is a grand conspiracy in that Bitcoin may be a long game where the US government is trying to corral all the criminals into a tight space where one sucker punch will bring many undone. Alas, government incompetence and Hanlon's razor makes this unlikely. Yet, it makes me go, "Hmmm."

Virtual currencies are a cesspool that need not be so. Regulators are belatedly picking up the ball, but not fast enough. ICOs and the vulnerability of poorly educated retail are one dimension but I worry more about crime. You should too. This is a thing that should make us all go, "Hmmm."

Nasdaq's IEX patent suit meanders on

There is no reals news to meander here.

In response to the suit, IEX filed for a dismissal, as is normal practice. Nasdaq responded on 10th July with a response to the dismissal:


PDF of the fifty-page filing
(click to enlarge)

All the normal course of events in pre-trial manoeuvrings. Nothing to see here. You may meander over the entrails as you wish.

Happy trading,


Wednesday, 11 July 2018

NYSE takes the gloves off: IEX

Apologies for a short meander on IEX. I agree with you. It is getting tiring...

I must say I'm hoping the IEX board takes on their problem so we don't have to worry about such IEX hyperbole and mendacity for much longer. The prospect of a down round may help focus the board's mind.

Anyhow, the latest comment letter from NYSE on the dumb fee pilot was a pointed rebuttal of IEX's false and misleading claims. Hat tip to Mr Osipovich for the heads up:

NYSE's conclusion was strong and clear (page 14):
"In the real world, the IEX model has failed. It trades mostly in the dark, has no listings, and has not achieved its promised growth. If there were truth to the IEX narrative, or if its model created significant value, it would have been more successful. Blaming competitors whose business models work and lodging false accusations do not change objective facts.
Respectfully submitted,

The start was strong too (page 1):
Two years ago, Investors Exchange LLC (“IEX”) was an ATS that traded roughly 2% of US equity volume, consisted of about 80% dark trading activity, and listed zero securities. Two years later, it is an exchange that trades roughly 2% of US equityvolume , consists of about 80% dark trading activity, and lists zero securities.
By any objective measure, IEX has failed to have a meaningful impact as an exchange. So how does it try to cling to relevance when its high-cost, low-volume business model is jeopardized? By blaming others and disparaging NYSE’s name to attract attention.
Generally, we have chosen not to respond to IEX’s business-driven marketing ploys. But now IEX has sunk to a new low. For its own commercial interest, the so-called “Investors Exchange” propagates a lie that the proposed Transaction Fee Pilot 1 would have no impact on displayed prices in the market and thus no impact on investors or issuers. We have no choice but to respond.

The gloves are definitely off. Not before time.

You should just read the letter if you have time, but here are some cherry-picked fun pieces to meander through:

Is IEX abusing the SEC comment process?

With its business model clearly failing despite its initial fanfare, IEX has resorted to making a mockery of the Commission’s comment process in an attempt to ingratiate itself with the media, order flow providers, companies, and regulators.

Is the NYSE misleading issuers? Is IEX offensive?

In its letter, IEX repeatedly states that because certain investors have submitted positive comment letters, NYSE is purposefully misleading issuers and investors with its analysis of investor harm. This is untrue and offensive.

Does IEX impugn NYSE's integrity?

Against this broad and well-reasoned opposition, IEX opts to accuse NYSE of fearmongering and breaching the trust of issuers. Those outcries beg an obvious question: Why is IEX choosing to impugn NYSE’s integrity? One clue might be that when IEX wrote its first comment letter supporting the Proposal without attacking NYSE, it failed to generate publicity. It fared better in its second swing.

On co-location, one of IEX's biggest flaws:

Likewise, the NYSE Group co-location services provide regulated, equal access to our market data and trading platforms, access that neither dark pools nor IEX provide. For all of IEX’s claims of fairness, it has no control over either how customers gain access to IEX at the first IEX entry point or the costs associated with getting closer access to that entry point. It is remarkable that IEX accuses other exchanges of “selling speed,” while it facilitates unequal access to its POP through a lack of regulated co-location space.

IEX claims issuers are dumb sheep:

Notwithstanding IEX’s smear campaign and accusation that we are purposefully misleading issuers, over two dozen listed companies have chosen to submit comment letters opposing the Proposal. Companies that have met the NYSE-listing standards are sophisticated and self-interested actors. If they choose to write a letter opposing the Proposal, it is because they have independently concluded that it is in their best interest to do so (and for reasons similar to why ETF issuers have expressed that they do not want an ETF included in a test bucket). To insinuate, as IEX has, that they are naïve or were misled is offensive to issuers.

IEX fiction on NYSE on MMs:

IEX next turns to fiction, claiming that NYSE believes that liquidity is posted only by electronic market makers. NYSE Group never took that position. In fact, rebates on NYSE and NYSE Arca are available to any liquidity provider.

IEX wants to shut out brokers and insist on friendlier routing. Does IEX need to submit yet another rule filing?

IEX takes the untenable position that even with disclosures, investors would not be in a position to know whether or how much fee conflicts may have impacted routing of their orders. This runs contrary to how institutional investors already demand detailed trade cost analyses (“TCA”) from their brokers and that brokers already readily provide data and analysis to such customers. Institutional investors employ numerous considerations in determining which broker to use and readily have the ability to find a broker that satisfies any demands for transparency in routing decisions.
Potentially IEX makes this nonsensical claim so that it can promote its forthcoming commercial TCA offering. We look forward to the rule filings IEX will submit to introduce this service as a facility of the exchange.

I think it is a technical knockout in favour of the NYSE. You?

Happy trading,


IEX - rope a dope

All you get for expending energy at times
of risk is stupidly high unauditable fees

which come back to hit you in the face
IEX published quite a funny delusional piece today.

"Between the Bells" by Allison Bishop of IEX.

I really don't know what to say. It is so silly it kind of tries to hang itself in the air like a brick but finds it doesn't. Quite weird really. The staff must be feeling some pressure.

Check out this chart of "Signal progress":

(click to enlarge)

Amusingly this discloses that on an unweighted tick percentage IEX is wrong around 75% of the time. They are right, it is a vast improvement over their up to Q1 2017 performance which was wrong 90% of the time.

When you pay your super high crummy crumbling quote instability fees that you can't reconcile nor audit, you may rest in the comfort there is a 75% chance such a fee was inappropriately applied. I don't think that will give you joy when reviewing your unchallengeable invoices.

Then IEX admits it hampers price discovery and being able to manage your risk with this dubious bit of meandering:
"55% of IEX volume trades at the midpoint, and only 5% of this occurs within 2 milliseconds of a price change. For contrast, on the maker-taker exchanges, up to 54% of midpoint trading occurs within 2 ms of a price change.[1] That’s a little crazy when you consider that one of the main goals of midpoint trading is to execute without moving the market."
IEX admits here they prevent their clients trading as the price changes. They admit they limit the ability of their clients to manage risk at the important times in a market, you know those time where the price is changing. IEX is admitting that they see their purpose as a public exchange to hamper the price discovery process.

You can read my recent pieces on how dumb the IEX crumbling quote logit formulae and technical architecture are:

It is a shockingly poor and quite an embarrassing quantitative and technical infrastructure. The balance between delusional and dishonest is hard to tell as there is certainly a bit of both. An unbalanced ship or mind is not a healthy thing to deal with as a client of IEX. Be aware and beware.

Be wary of the exchange on the rope. Don't be the dope.

Happy trading,


Friday, 6 July 2018

Will it be the usual quiet summer or will the trade wars spike volumes?

Most summers, but not all, have quiet markets.

A normal lead up to summer for this year would have seen a June NMS daily notional turnover of $290-300 billion. Instead, we saw an unusually high daily notional turnover of $350.10 billion for June.

(click to enlarge)
Then again, the July 4th holiday punctured this week with the first three days only averaging only $257.06 billion in turnover.

Will the unusually high June turnover continue? Trade war talk certainly suggests so, but it is time for your summer holiday...

Happy trading,


FCM & Retail FX Rankings US Futures Commission Merchants and Retail Foreign Exchange Dealers by Customers’ Segregated Assets

US Futures Commission Merchants and Retail Foreign Exchange Dealers by Customers’ Segregated Assets

May 31st 2018

Rank Futures Commission Merchant / Retail Foreign Exchange Dealer Registered As DSRO Adjusted Net Capital Net Capital Requirement Customers’ Assets in Seg
1 Goldman Sachs & Co Llc FCM BD SD CBOT/NFA 16,865,138,373 2,456,565,163 20,655,415,711
2 Jp Morgan Securities Llc FCM BD SD CEI/NFA 15,891,225,690 2,882,335,187 19,261,562,241
3 Morgan Stanley & Co Llc FCM BD SD CME/NFA 13,196,403,379 2,411,184,839 15,698,527,132
4 Merrill Lynch Pierce Fenner & Smith Incorporated FCM BD CBOT 12,353,320,200 1,759,685,363 14,915,844,477
5 Sg Americas Securities Llc FCM BD CME 4,084,553,402 1,443,571,895 14,632,596,312
6 Citigroup Global Markets Inc FCM BD SD CBOT/NFA 9,477,757,170 2,440,773,295 8,881,218,468
7 Credit Suisse Securities (Usa) Llc FCM BD CBOT 8,247,966,238 1,457,225,122 5,939,538,116
8 Ubs Securities Llc FCM BD CBOT 5,543,794,278 584,162,080 5,718,814,252
9 Barclays Capital Inc FCM BD NYME 5,155,089,573 931,180,520 5,309,357,099
10 Interactive Brokers Llc FCM BD CME 4,377,794,429 493,617,941 4,327,047,072
11 Adm Investor Services Inc FCM CBOT 306,184,234 175,780,072 4,308,882,464
12 Rj Obrien Associates Llc FCM SD CME/NFA 206,438,141 137,191,526 3,887,207,804
13 Wells Fargo Securities Llc FCM BD CME 7,910,218,483 819,740,847 3,458,964,548
14 Mizuho Securities Usa Llc FCM BD SD CME/NFA 729,628,079 237,751,427 3,119,064,086
15 Abn Amro Clearing Chicago Llc FCM BD CBOT 665,526,030 174,058,386 3,102,598,874
16 Bnp Paribas Securities Corp FCM BD CBOT 2,579,869,502 345,324,367 3,087,263,216
17 Intl Fcstone Financial Inc FCM BD CME 153,102,903 94,013,336 2,469,456,871
18 Deutsche Bank Securities Inc FCM BD CBOT 12,174,368,017 278,876,362 2,434,419,623
19 Hsbc Securities Usa Inc FCM BD CME 973,678,363 289,122,781 2,147,700,321
20 Macquarie Futures Usa Llc FCM CBOT 258,886,048 162,900,062 2,137,486,167
21 Merrill Lynch Professional Clearing Corp FCM BD NFA 4,370,243,087 564,309,966 2,084,412,288
22 Rbc Capital Markets Llc FCM BD CME 2,030,382,529 172,846,617 1,645,695,556
23 E D & F Man Capital Markets Inc FCM BD CME 158,100,009 54,827,484 1,498,977,853
24 Rosenthal Collins Group Llc FCM CME 90,822,333 56,980,202 1,335,456,829
25 Wedbush Securities Inc FCM BD CBOT 176,442,166 32,214,977 1,331,439,983
26 Santander Investment Securities Inc FCM BD NYME 207,145,654 50,000,000 804,373,009
27 Mcvean Trading & Investments Llc FCM NFA 14,029,643 2,347,171 796,903,849
28 Natwest Markets Securities Inc FCM BD CBOT 1,162,745,003 34,619,450 637,813,752
29 Tradestation Securities Inc FCM BD CME 89,367,053 4,743,023 581,546,832
30 Advantage Futures Llc FCM CME 21,771,259 5,899,124 320,499,311
31 Td Ameritrade Futures & Forex Llc FCM NFA 120,915,845 22,951,710 288,242,468
32 Phillip Capital Inc FCM BD CME 33,300,220 12,150,257 283,104,509
33 Nomura Securities International Inc FCM BD CBOT 2,084,633,210 218,715,380 240,494,937
34 Gain Capital Group Llc FCMRFD NFA 47,373,192 34,688,201 223,833,727
35 Straits Financial Llc FCM CME 22,486,946 6,459,380 204,678,142
36 Marex North America Llc FCM CME 22,062,196 17,144,451 203,136,036
37 Efl Futures Limited FCM CME 44,529,906 17,222,992 200,768,188
38 Rand Financial Services Inc FCM CME 88,955,840 11,581,057 174,707,000
39 Chs Hedging Llc FCM CBOT 48,746,365 11,009,072 169,438,192
40 Ubs Financial Services Inc FCM BD NFA 1,190,512,451 121,195,743 165,973,600
41 Dorman Trading Llc FCM CME 12,992,415 1,022,698 152,237,575
42 Gh Financials Llc FCM CME 23,172,158 5,515,488 115,176,347
43 Charles Schwab Futures, Inc. FCM NFA 96,390,988 4,214,409 114,194,013
44 E*Trade Futures Llc FCM NFA 26,238,908 2,281,598 68,760,230
45 Cunningham Commodities Llc FCM CBOT 5,136,618 1,000,000 65,945,970
46 Ironbeam Inc FCM NFA 3,143,322 1,508,722 64,164,242
47 Uobbf Clearing Limited FCM CME 26,459,310 3,002,272 59,865,140
48 Nanhua Usa Llc FCM CME 16,746,261 2,267,066 55,316,343
49 Amp Global Clearing Llc FCM NFA 3,803,628 1,000,000 53,585,178
50 Mid Co Commodities Inc FCM NFA 9,598,285 5,052,795 49,787,456
51 York Business Associates Llc FCM NFA 5,433,181 1,000,000 43,999,369
52 Boci Commodities & Futures Usa Llc FCM CME 7,732,176 1,042,048 25,005,405
53 Apex Clearing Corporation FCM BD NFA 180,879,973 24,342,679 10,852,760
54 Cantor Fitzgerald & Co FCM BD CBOT 290,661,200 12,797,253 4,969,921
55 Daiwa Capital Markets America Inc FCM BD CME 639,214,765 10,656,265 2,172,539
56 Pictet Overseas Inc FCM BD NFA 16,198,361 1,873,629 2,112,838
57 Jefferies Llc FCM BD NFA 1,666,879,280 106,210,437 0
58 Scotia Capital Usa Inc FCM BD CME 925,420,659 55,107,063 0
59 Oanda Corporation FCMRFD NFA 88,548,953 54,139,208 0
60 Bgc Financial Lp FCM BD NFA 54,754,295 1,888,384 0
61 Bofaml Securities Inc FCM NFA 25,000,000 1,500,000 0
62 Huatai Financial Usa Inc FCM NFA 2,124,510 1,000,000 0
63 Mint Brokers FCM BD NFA 2,674,276 1,000,000 0
64 Direct Access Usa Llc FCM NFA 2,906,641 1,000,000 0

Sourced from: US Commodity Futures Trading Commission - Financial Data for FCMs

Futures Commission Merchant that is registered with the Commodity Futures Trading Commission;
The FCM is also registered with the Securities and Exchange Commission as a securities broker or dealer;
Retail Foreign Exchange Dealer that is registered with the Commodity Futures Trading Commission;
The FCM is also registered with the Commodity Futures Trading Commission as a Retail Foreign Exchange Dealer.
This column identifies the firm’s Designated Self-Regulatory Organization (DSRO). A DSRO is the organization that is primarily responsible for conducting audits of and ongoing financial surveillance over the firm. A DSRO can be a designated contract market (DCM) or the National Futures Association.
Adjusted Net Capital
This is the amount of regulatory capital available to meet the FCM’s minimum net capital requirement. The classification of assets and liabilities used in arriving at net capital, and the additional capital haircuts that a FCM may be required to take, are set forth in CFTC Regulation 1.17.
Net Capital Requirement
The minimum net capital that each FCM must maintain is determined under CFTC Regulation 1.17(a)(1)(i). Refer to pages 7-11 through 7-12 of the Form 1-FR-FCM Instructions for more information regarding how to compute the net capital requirement.