Legal & Regulatory

TTG operates within the financial services community, but TTG itself does not carry out any regulated activities and consequently is not required to be authorised by the Financial Conduct Authority. All of TTG’s preferred clearers do conduct regulated activities and are authorised to do so by the Financial Conduct Authority. Please read the information below for a more detailed explanation of our structure.

TTG is entirely transparent in all its trader dealings. Before entering into contractual terms with any prospective new trader TTG provides clear and simple guidance on its business model and position within the market. That business model is based on facilitating trader business through TTG’s preferred clearers. TTG’s current preferred clearers are Marex Spectron (http://www.marexspectron.com) and Societe Generale Corporate & Investment Banking (http://www.sgcib.com), market leading clearing firms. TTG is able to enter into clearing agreements with such firms on commercial terms not typically available to individuals. Those clearing terms allow TTG to appoint nominated individuals –i.e. you the trader- to trade via accounts held in TTG’s name with its preferred clearers.

Due to recently introduced requirements under Article 39 of the European Market Infrastructure Regulation all clearing firms are obliged to offer their customers a choice of account-type at the CCP (Central Counter Party Clearing House) through which the customers’ transactions are cleared. The choice is between an omnibus account (“OSA”) and an individual account (“ISA”). The differences are quite complex but in summary, an omnibus account (“OSA”) offers the protection of segregation from the clearer’s house positions at the CCP, but otherwise is essentially a pooled funds structure, whereas an ISA is akin to full segregation requiring the CCP to hold a separate account for the customer in the CCP’s books and records.

The vast majority of TTG’s business with its clearers is conducted through OSAs, but subject to availability and costs ISAs can be set up on bespoke basis. To facilitate the OMA structure full legal title to all trader funds must pass to TTG before TTG deposits the same with its preferred clearer. This means that any positive trading balance associated with an individual trader account is recorded in TTG’s creditor ledger and a corresponding debt owed to such designated trader which will be satisfied when a trader makes a draw down request. Accordingly, all traders conducting business with TTG agree that all funds transferred to TTG shall not be treated as “client money” in accordance with client money rules and will not be subject to the protections conferred by those rules. As a consequence, trader funds will not be individually segregated and will be pooled by TTG with other trader funds deposited with TTG’s preferred clearers in the ordinary course of business.

Full terms and conditions can be made available on request.

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