Kürzlich sprachen wir mit Rafael Neustadt, Geschäftsführer des deutschen CFD Verbandes und Geschäftsführer der FXFlat Wertpapierhandelsbank GmbH im. FXFlat ist Mitglied im Contracts for Difference Verband e.V., kurz CFD-Verband. Contracts for Difference Verband e.V. auf der Neue Mainzer Str. in. Welche Einlagensicherung und in welcher Höhe vorliegt, ist auf der Website des jeweiligen Verbandsmitglieds sowie auf der Website des Hippodrome casino london unter www. Mitglieds- Presse und jegliche Auskunfts- Anfragen richten Sie gerne an: Die Anzahl der Konten legte gegenüber dem Vorjahr um 28 Prozent zu, von gut Anlegerschutz hat höchste Priorität. Je nach Produktausgestaltung spielstand braunschweig unter extremen Marktbedingungen so für den Kunden eine Nachschusspflicht entstehen, d. Denn sie sollen zur Verlässlichkeit des Anlegerschutzes beitragen. The CFD Association is supportive of improved restrictions on aggressive marketing practices. What impact do you consider that the introduction of leverage limits on the basis described falstaff casino bregenz applying to retail clients only would have on your business? Furthermore, the view that there is a lack of transparent information at point of sale is incorrect. New online casino games 2019 casino-parkhaus bad homburg vor der höhe with negative balance protection, client information and restriction of aggressive marketing practices the risk for retail clients will be manageable. In particular, what impact do you consider that assigning a leverage limit of 5: Prior to opening a new position the margin will be calculated in order to allow such trade in book of dead gewinne of the current balance on the account. Under the australian online casino quick payout per-position rule, this constitutes a leveraged position. Do you believe that specific restrictions concerning CFDs in cryptocurrencies should be introduced? What impact do you consider that a restriction on incentivisation of trading werder transfernews to retail clients only would have on your business? According to said study,
The market study published by the CFD Association has additionally shown that CFD investors have a very high level of skill and education.
According to said study, Furthermore, the economic situation of clients is good. As such, the CFD Association questions whether such a protection is necessary for CFD clients who have deliberately decided to trade in CFDs and have comprehensive knowledge in this field.
The CFD Association is of the view that negative balance protection on a per account basis applying to retail clients only is the measure providing the best level of protection for clients as unlimited losses are avoided.
It is sensible to calculate the balance at risk on a gross basis, i. Negative balance protection on a per account basis applying to retail clients only has already been implemented in Germany.
Prescribed disclosures setting out the total costs of the product. As mentioned in the Consultation Report, firms in Europe are required to disclose to the client the total cost of the product as part of enhanced disclosure requirements stemming from the MiFID II legislation.
In addition, firms offering the relevant products are required to provide other standardised disclosures to their clients, including information on the objectives of the product, target market and costs and charges as set out in the Regulation on Key Information Documents for Packaged Retail and Insurance-based Investment Products PRIIPs.
The CFD Association is fully supportive of the full disclosure of the risks associated with such products. However, the CFD Association would make the following observations in respect of any proposal to require the disclosure of profit and loss statistics for CFD investors.
Firstly, the Consultation Report states that the provision of such information would support clients in making an informed decision about whether they wish to proceed with a high-risk product that, statistically, is more likely to result in a loss than a gain.
However, in the opinion of the CFD Association, the aforesaid studies are not applicable to Germany, as the German market is dominated by highly regulated providers and has a much smaller number of unregulated providers.
This study has also been presented to BaFin and is available to the latter. According to said study, only Secondly, the CFD Association would be wary of requiring the disclosure of profit and loss ratios solely in the case of the products on which the Consultation Report focusses.
The Consultation Report also focusses on the complexity of the products. There is a 1: An investor who trades a large volume can expect that the risk involved corresponds to the volume traded.
Therefore, applying additional disclosure requirements to CFDs as compared to its competitor products would put it an unnecessary competitive disadvantage.
As such, requiring such specific disclosure for CFD investors may be regarded as a disproportionate response for investors who have deliberately decided to trade in CFDs and have comprehensive knowledge in this field.
Adoption of a fair pricing methodology and use of externally verifiable price sources. As the Consultation Report states, European investment firms are required to demonstrate fairness in pricing when executing in OTC products and have increased transparency around execution processes as part of the best execution requirements arising from MiFID 2.
As the Consultation Report states, European firms are required to disclose their order execution policy to their clients as part of their best execution requirements.
The requirement for firms to disclose their pricing methodology is also consistent with the spirit of the legislation. The enhanced best execution requirements in MiFID II require investment firms, including brokers, to make public the top five execution venues where they execute client orders and information on the quality of execution obtained.
Execution venues are also required to make public detailed data relating to the quality of execution of transactions on that venue.
A ban or restrictions on certain forms of marketing and sales techniques for the relevant products. The CFD Association is supportive of improved restrictions on aggressive marketing practices.
Most jurisdiction have already regulation in place like MiFID II legislation or apply the general rule against unfair competition e.
Accordingly, while the CFD Association is supportive of improved restrictions on aggressive marketing practices, it believes that such improved restrictions will be most effective if targeted specifically at unregulated or insufficiently regulated providers.
Please find below our response to the aforesaid Call for Evidence. As an association of 12 leading providers offering CFDs in Germany, who represent a significant portion of the German overall market, potential product intervention measures may affect our economic and legal interests, or rather those of our members.
This is why individual members reserve the right to submit their own statements in this Call for Evidence. As a rule, the CFD Association and its members welcome measures to improve investor protection.
According to information from BaFin, about complaints were made in with regard to providers regulated by a supervisory authority in another EU Member State.
Such action would lead to more investor protection and would make it more difficult for non-serious providers to act on the market. Corrections to or concretisation of the statements of fact in the Call for Evidence.
The average CFD investor is not a typical retail investor. This definitely needs to be taken into account for the purposes of the Call for Evidence.
The CFD Association is aware of these studies. In the opinion of the CFD Association, the aforesaid studies are not applicable to Germany, as the German market is dominated by highly regulated providers and has a much smaller number of unregulated providers.
This shows again that the focus should be on regulating the marketing practices of CFD providers rather than on imposing restrictions on the product.
According to the Call for Evidence, there is a significant risk of loss both from trading and from transaction fees , which is magnified by the effect of high leverage.
In addition, the transaction fees are within the customary range for similar financial products. According to ESMA, the complexity of these products and a lack of transparent information at point of sale limit the ability of retail investors to understand the risks underlying these products.
CFDs are not complex products; or rather the performance calculation for CFDs is not a complex issue. Furthermore, the view that there is a lack of transparent information at point of sale is incorrect.
Criticism about the timing of the consultation and the little time allowed for furnishing a statement. This Regulation provides that a key information document must be published for a PRIP or packaged retail investment product by the manufacturer of the product before the product is offered to retail investors.
The key information document should focus on the key information that retail investors need. The key information document contains sections regarding, amongst other things, the risks of the product, potential performance scenarios, the costs and a description of the type of retail investor to whom the product is intended to be marketed, in particular in terms of the ability to bear investment loss and the investment horizon.
According to that Directive, a so-called product approval process is intended to specify an identified target market of end clients within the relevant category of clients for each financial instrument and to ensure that all relevant risks to such identified target market are assessed and that the intended distribution strategy is consistent with the identified target market.
In determining the target market for CFDs, the following information is of particular importance:. Furthermore, MiFID 2 now provides for comprehensive cost transparency through ex ante information about all costs and associated charges of the financial instruments.
Against this background, and also in light of the large number of new transparency obligations and investor protection requirements in respect of financial instruments and packaged investment products for retail investors and, hence, also in respect of CFDs, the point in time chosen by ESMA for its Call for Evidence is incomprehensible and must be strongly criticised.
To date, ESMA has not gained any insights as to the implementation and impact of the relevant investor protection and transparency requirements in the case of CFDs.
However, such insights imperatively need to be taken into account when exercising discretion in the context of product intervention measures.
Exercising discretion without taking such necessary and relevant new information into account would mean exercising such discretion incorrectly.: Furthermore, a product intervention by ESMA has far-reaching consequences for the rights of the parties involved, which is why said parties need to be heard comprehensively and sufficiently.
Consultations launched by ESMA typically take several months. The simultaneously running public consultation on building a proportionate regulatory environment to support SME listing, for example, provides for a consultation period of clearly above two months.
Such a short period of time for statements in connection with a measure as incisive as the first product intervention intended by ESMA is inappropriate and disproportionate.
Please find below our responses to the questions raised by you in your Call for Evidence. Do you think that ESMA has adequately identified the instruments in the scope of its possible measures?
The effect of leverage, which has received special criticism from ESMA, also exists with numerous other packaged retail investment products e.
Also, the concept of unlimited personal liability is embedded in many other products like options and futures. This even extends to the example of mortgages, where the liability may exceed the value of the underlying object.
What impact do you consider that the introduction of leverage limits on the basis described above applying to retail clients only would have on your business?
Please describe and explain any one-off or ongoing costs or benefits. However, as a result of leverage being limited, there would subsequently be a very significant fall in returns.
Such a loss of clients could jeopardise the continued existence of providers offering CFDs and of CFD brokers, in particular in cases where the trade in CFDs accounts for a large portion of their business, and, for the firms concerned, would constitute a significant interference with the fundamental right to carry on an established business protected fundamental rights: It is feared that if ESMA imposes even stricter margins, the shares prices of listed companies might fall even more drastically.
For smaller providers the announced measures could be existence-threatening. The Japanese regulator foresees a leverage limit of The US regulator foresees a leverage limit of Investors staying with EU regulated distributors despite the burden of the measures and wishing to achieve an equivalent trade volume upon leverage being limited would have to invest a multiple of the capital currently invested, which would have to be withdrawn from other types of investment, such as savings accounts.
Because of the larger amount of capital invested, they would now be forced to invest their capital using only one strategy or only few different strategies, which would give rise to a higher risk of loss.
What impact do you consider that the introduction of a margin close-out rule on a per-position basis applying to retail clients only would have on your business?
The CFD Association expects a very high one-off cost in this regard specification, programming and testing. Such sums particularly jeopardise the continued existence of comparatively small providers and brokers.
The members expect that they will need 3 to 6 months, some of them even 9 to 12 months, to implement a margin close-out rule.
In light of the very high cost of implementation and the enormous amount of time needed for this purpose, it is feared that the providers and brokers concerned will relocate to non-EU countries.
The ongoing costs of a margin close-out rule cannot be foreseen; in this respect, the providers especially state that such a rule makes reasonable hedging in relation to such positions impossible — both for the provider and for the client.
Such a rule deprives the client of the option to define its own stop-loss limits and to deliberately accept a higher potential for loss.
Under the proposed per-position rule, this constitutes a leveraged position. Such a rule would place CFDs at a disproportionate disadvantage, compared to all other financial instruments.
This would be a loss of This example shows that such a rule produces absolutely disproportionate results. What impact do you consider that the introduction of negative balance protection on a peraccount basis applying to retail clients only would have on your business?
What impact do you consider that a restriction on incentivisation of trading applying to retail clients only would have on your business?
The CFD Association would welcome a restriction on incentivisation of trading. The CFD Association is of the opinion that incentivisation of trading primarily attracts inexperienced clients; experienced traders are less influenced by such offers.
Therefore, the CFD Association takes the view that a restriction on incentivisation of trading, when the incentivisation is generally only attracting clients to start trading or entrap the client to do more trading, would be an appropriate measure for investor protection.
A restriction on incentivisation would additionally ensure a level playing field among CFD brokers, in the opinion of the CFD Association.
What impact do you consider that a standardised risk warning applying to retail clients only would have on your business? A standardised risk warning would give rise to only a small amount of one-off costs and ongoing costs.
The members of the CFD Association would welcome a standardised risk warning for all market participants with a view to creating a level playing field.
Please provide evidence on the proportion of retail clients that use these products for hedging purposes and how the suggested measures will affect them.
According to the aforementioned market study conducted and published by the CFD Association, An increase in margin requirements and a restriction in the close out rule could make proper hedging completely impossible for clients as it would require more capital or would mean, that hedges are closed while the original position is still held.
What impact do you consider that a prohibition on providing binary options to retail clients would have on your business?
The CFD Association is always voting against a product prohibition but suggest for better client education and information as well as restriction of aggressive marketing practices.
What impact do you consider that the envisaged measures would have on retail investors? We would like to make reference to our responses to previous questions which cover this issue.
The members of the CFD Association particularly fear that a leverage limit might result in investors turning to unregulated providers outside the EU.
One difference between the products is that one has to open a margin account with a provider to trade CFDs whereas for structured products one only need to open an account with a broker such Cortal Consors or Flatex to access all the products from 15 major issuers, as well as smaller providers.
The market for CFDs is still relatively small compared to the market for leveraged structured products offered by the major banks although CFD providers have increased their marketing spend to attract more online day traders.
For most CFD providers in Germany, building links with the online local brokerages is crucial — even though investors may also deal directly with their online trading platforms.
IG advertises heavily in local retail finance magazines and also runs campaigns at Eintracht Frankfurt football stadium.
In Germany much of the action is concentrated on major stock indexes with the bulk of trading being on the DAX rather than other European indexes.
The number of customer accounts had reached 36, by the end of [latest figures March , estimate the figure to 70,] but this is still very small compared to the number of certificate customers.
That the proliferation of CFDs is still far behind that of the certificates market can be justified by the enormous competition from the certificates market, which is founded in Germany by major international banks as issuers.
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Industry Having been introduced to Germany in , contracts for difference in german known as a contract for differenz have grown in popularity since the financial implosion, taking market share away from an even more popular trading instrument known as Zertificaten Certificates , which, like contracts for difference, offer short-term traders leveraged exposure to market risk but without the counterparty guarantees of central clearing.
CFD Verband The number of customer accounts had reached 36, by the end of [latest figures March , estimate the figure to 70,] but this is still very small compared to the number of certificate customers.