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ASIC has developed seven disclosure benchmarks for over-the-counter contracts for difference (OTC CFDs) to assist retail investors understand the risks associated with these products, assess their potential benefits and decide whether investment in the products is suitable for them.
As an issuer of OTC CFDs CMG Australia Pty Ltd. provides the information set out below to explain whether and how it addresses the benchmarks.
These disclosures are a summary only and should not be relied upon solely. The Product Disclosure Statement (PDS) sets out the information in detail and is available on this website. Clients should ensure they review the PDS in full before deciding whether to acquire CMG Australia Pty Ltd.’s products.
Benchmark 1: Client Qualification
CMG Australia Pty Ltd. operates a client qualification policy that is designed to ensure that Australian resident clients have appropriate experience in or knowledge and understanding in CMG Australia Pty Ltd.’s derivative products. This policy has been developed by reference to ASIC Regulatory Guide 227 and best industry practice.
Applicants can demonstrate appropriateness by satisfying one of the three criteria below:
Demonstrated trading experience in the same or similar products; or
Pass a multiple choice quiz designed to demonstrate adequate knowledge of the products and financial markets; or
Complete a training course that meets the minimum requirements.
A diagrammatic explanation of the above exists further down the page.
1. Sufficient Trading Experience
In order to establish that an individual has had appropriate experience, account applicants must be able to demonstrate all of the following. That they have:
Within the past three (3) years, operated a Margin Forex or CFD or Futures account; and
Had at least two months of trading experience; and
Conducted at least 20 transactions on a non-advised basis.
If a potential client fails to completely satisfy all three of the above criteria, then they either attempt the quiz (part 2) or attend a training course (part 3)
2. Multiple-choice quiz:
In order to qualify as a potential client for CMG Australia Pty Ltd., you must record a pass score (of 70% or greater). The quiz consists of 10 (ten) multiple choice questions, with at least one correct answer required from each of the following sections:
Previous experience in investing in financial instruments, including securities and derivatives.
Understanding of the concepts of leverage, margins and volatility.
Understanding of the nature of CFD trading.
Understanding of the processes and technologies used in trading.
Preparedness to monitor and manage the risks of trading.
CMG Australia Pty Ltd. has a large pool of suitable questions for each category from which the quiz questions are selected. These questions are altered each time the quiz is taken.
If a mark of 70% or greater is achieved, you will be deemed qualified to trade through CMG Australia Pty Ltd. If a pass grade is not achieved, then you will be required to complete a training course, as per part 3.
3. Training Course:
To be deemed eligible to trade with CMG Australia Pty Ltd., an individual must undertake and complete a training course that satisfies the following criteria:
A duration of 8-16 hours
If the course does not meet the minimum time required, then it will be deemed an insufficient qualification
Regulated by ASIC
The provider must operate under an AFSL that allows them to provide general financial product advice.
Provides ongoing support and coaching for a minimum 6 (six) week period.
You must provide CMG Australia Pty Ltd. with a copy of your certificate of completion.
If a training course fulfills all three of the above requirements, then an individual will be deemed qualified to trade with CMG Australia Pty Ltd.
If you cannot fully satisfy one of the aforementioned elements, then you will not be considered qualified to be a client with CMG Australia Pty Ltd.
Benchmark 2: Opening Collateral
CMG Australia Pty Ltd. offers a full suite of payment options for clients to fund their accounts.
CMG Australia Pty Ltd. provides credit card funding for the ease of providing secure electronic payment system to its clients. This is used for both instantaneously funding accounts and meeting margin calls.
CMG Australia Pty Ltd. does not encourage the use of leverage products with borrowed funds.
CMG Australia Pty Ltd. does not accept “cash equivalents” as opening collateral (e.g. no securities as deposits).
CMG Australia Pty Ltd. has chosen not to comply with ASIC’s suggested benchmark on Opening Collateral requirements, which suggest limiting initial funding by credit card to a maximum of $1000.
Benchmark 3: Counterparty Risk (Hedging)
Within CMG Australia Pty Ltd.’s risk management framework we have assessed the market risk and counterparty risks arising from entering into OTC CFD transactions with customers and hedge counterparties and applied controls to mitigate those risks. Those controls include:
the enforcement of leverage limits based on the account equity of the client and the instruments being traded;
the enforcement of market risk limits on the net exposure and daily loss limits of CMG Australia Pty Ltd.;
the selection of hedge counterparties, in sufficient number to give reasonable assurance that CMG Australia Pty Ltd. has adequate facilities and capacity to hedge its exposures; and
the selection and maintenance of hedge counterparty relationships based on, amongst other things, their financial capacity and resilience.
CMG Australia Pty Ltd.’s selection of hedge counterparties is based on the following factors:
whether the funds placed by CMG Australia Pty Ltd. as collateral are subject to Segregation;
the counterparties’ financial strength and stability based on its credit rating and that of its parent (if any);
the regulatory status of the counterparties and whether they are Australian Authorised Deposit-taking Institutions (ADIs); and
the services it provides and the strength of its operational controls and systems.
CMG Australia Pty Ltd.’s hedge counterparties at the time of publication are:
Royal Bank of Scotland
INTL FC Stone Inc.
Sucden Financial Limited
Clients are indirectly exposed to counterparty risks notwithstanding these protections and should review the disclosures in the risk warning section of CMG Australia Pty Ltd.’s Product Disclosure Statement and refer also to the Client Agreement.
Benchmark 4: Counterparty Risk (Financial Services)
CMG Australia Pty Ltd. maintains a written policy and procedure with regard to the management and ongoing monitoring of its financial resources. This written policy addresses the following matters, amongst other things:
the methodology employed by CMG Australia Pty Ltd. to measure and assess its regulatory financial requirements under its Australian Financial Services License;
linkages between the budgetary planning process and the financial requirements;
scenarios used to forecast the cash resources available to CMG Australia Pty Ltd. to meet its financial requirements; and
roles and responsibilities for measuring and monitoring the financial condition against the requirements.
To mitigate the risks of failing to satisfy the financial requirements under its license and to provide assurance that CMG Australia Pty Ltd. has sufficient financial resources at all times, the firm:
has established an internal requirement to maintain a capital buffer over and above the external regulatory requirement;
measures and monitors the internal buffer and the external financial requirements against the firm’s actual financial condition on a daily basis; and
subjects the firm’s financial condition to quarterly scenario tests to assess compliance with the regulatory capital requirements and its ongoing financial needs under stressed conditions.
Benchmark 5: Client Money
This information is made available by CMG Australia Pty Ltd. to explain how client money is handled. The purpose is to provide clients with an insight into how client money is segregated and may be utilised by CMG Australia Pty Ltd. so that clients are better informed to assess the safety of their funds relative to other financial product providers.
Client money is held with Australian Authorised Deposit-taking Institutions (ADIs) in compliance with the Corporations Act Regulations.
Funds are not held in individual segregated accounts but are pooled with other client’s funds. CMG Australia Pty Ltd.maintains Client Segregated Trust Accounts in a number of currencies for this purpose.
Clients should take care to understand that our holding of client monies in one or more Segregated Accounts does not afford them absolute protection and that in the event of CMG Australia Pty Ltd. becoming insolvent clients become unsecured creditors of CMG Australia Pty Ltd.. A further discussion on this topic is available in section 7 of the Product Disclosure Statement and section 19.6 of the Client Agreement.
CMG Australia Pty Ltd. currently holds Client Segregated Trust Accounts with the following Banks:
National Australia Bank Limited
As an Australian Financial Services licensee, CMG Australia Pty Ltd. is permitted to pool client money in one or more accounts and use this money to meet collateral obligations it incurs with its hedge counterparties in relation to client transactions. Importantly, CMG Australia Pty Ltd. is permitted to deduct the initial margins due from its clients on their open positions for this purpose as well as other monies. We are not permitted to use these funds in any other way in our business.
CMG Australia Pty Ltd. maintains a Client Money Policy setting out the circumstances under which it is entitled under the Regulations to deduct monies from the Segregated Trust Accounts.
The Policy allows CMG Australia Pty Ltd. to use money deposited by one client to meet the margin or settlement requirements of another client. The pooling of Client funds in one or more Segregated Accounts in this way exposes clients to the risk of a deficit in the Segregated Account if one client or a group of clients fail to pay money they owe.
To ensure that the balance of funds held in Segregated Trust Accounts at least equals the balance of CMG Australia Pty Ltd.’s liabilities to its Clients, a daily reconciliation is performed. On the basis of the reconciliation, CMG Australia Pty Ltd. either pays to or withdraws money from the Segregated Trust Accounts reflecting the net settlement of all obligations to its clients. That reconciliation is subject to independent daily review.
In the event of CMG Australia Pty Ltd.’s insolvency and in the event that the daily reconciliation and settlement has not been performed, there may be a deficit in the Segregated Trust Accounts. It is for this reason that CMG Australia Pty Ltd. is required under the conditions of its Australian Financial Services Licence to have and to maintain sufficient financial resources of its own to mitigate the risk of its insolvency. Refer to Benchmark 4 – Counterparty Risk (Financial Resources).
Benchmark 6: Suspended or Halted Underlying Assets
Foreign exchange markets trade continuously. They open at 05:00pm American EST* Sunday evening (Monday morning NZ time) and close at 05:00pm, American EST** on Friday (Saturday morning NZ time). They are open 24 hours during this period.
Prices are continuously streamed during this period. Because foreign exchange is not an exchange-traded product, it is not possible to suspend or halt the streaming of these prices.
For our futures, commodities and index products, CMG Australia Pty Ltd. will halt client trading and the use of client money in an asset or derivative when a trading halt exists for the underlying asset, or trading in the underlying asset has been suspended through an exchange or otherwise.
* Eastern Standard Time (America)
Benchmark 7: Margin Calls
CMG Australia Pty Ltd. establishes minimum margin requirements for all instruments. These margin requirements are set out in the Product Schedule available on the website.
The MT4 trading system monitors the margin requirements of all open positions for each client against the client’s account equity. Clients can monitor their margin requirements and the margin ratio within the MT4 trading application.
Where account equity falls below the total margin requirement a margin call is generated and sent to the email address provided by the client to CMG Australia Pty Ltd.. Clients are advised that they must maintain sufficient equity to meet the total margin requirement at all times. We are not obliged to allow time to forward funds to meet Margin Calls as markets can be volatile and CMG Australia Pty Ltd. may without notice, in its discretion, close out all or some positions if the margin requirements are not satisfied. Whilst the account remains in margin deficit a Margin Call email will be sent every 30 minutes. Clients must ensure that they monitor their margin requirements as CMG Australia Pty Ltd. cannot guarantee that Margin Call emails will be received and should not rely on this.
Refer to Section 11 of the Client Agreement
If a client’s free equity falls below the Liquidation Level CMG Australia Pty Ltd. is entitled, but not obligated, to close all open positions. We do not guarantee that positions will be closed and clients are warned not to rely on CMG Australia Pty Ltd. to do so. We also cannot guarantee that if positions are closed by CMG Australia Pty Ltd. that a deficit on the account will be avoided. Clients must be aware that they remain liable for any debit balance arising on their account.
The Liquidation Level is currently 30% but is subject to change.
If CMG Australia Pty Ltd. does close positions then the position with the largest margin requirement will be closed first and then subsequently in descending order until the margin ratio is above the Liquidation Level.
Level 10, 90 Arthur Street,
North Sydney NSW 2060, Australia
P: +61 2 4036 3165
Risk Warning: CMG Australia Pty Ltd (ACN 618 480 998 & CAR No. 001256635) ‘CMG’, is a corporate authorised representative of AxiCorp Financial Services Pty Ltd (ACN 127 606 348 & AFSL No. 318232). Investing in over-the-counter derivatives carries significant risks and is not suitable for all investors. You could lose substantially more than your initial investment. When acquiring our derivative products, you have no entitlement, right or obligation to the underlying financial asset. CMG is not a financial adviser and all services are provided on an execution only basis. CMG is authorised to provide general advice only and information is of a general nature only and does not take into account your financial objectives, personal circumstances. CMG recommends that you seek independent personal financial advice. A Product Disclosure Statement (PDS) for our financial products and our Financial Services Guide (FSG) are available at www.cmgau.com or can be obtained free of charge by calling CMG. The PDS and FSG are important documents and should be reviewed prior to deciding whether to acquire, hold or dispose of CMG’s financial products or services. The information on this website is for Australian residents only.