RG 227 Disclosure Benchmarks — Thunder FX LTD
Thunder FX is an FCA-compliant global multi-asset broker, registered in England & Wales (No. 16523655), MSB registration (USA, FinCEN MSB Reg. 31000321940565) under the legal name Thunder FX Ltd, with registered address at 999 18th Street, Suite 3000, Denver, Colorado 80202, and SEC registered (No. 000207665). Thunder FX is committed to transparency, client fund protection, and regulatory best practice.
Regulatory Guide 227 (RG 227) issued by ASIC sets out 7 disclosure benchmarks for OTC derivative issuers. Below, Thunder FX details how each benchmark is met in accordance with our international licenses and best practices.
BENCHMARK REQUIREMENT EXPLANATION
CLIENT QUALIFICATION Yes Thunder FX maintains and applies a written policy which sets out the minimum qualification criteria that prospective retail investors will need to demonstrate before we will open a trading account for you. Thunder FX also maintains a written policy/procedure to ensure such criteria are properly applied, and unsuitable investors are not accepted. We also maintain records of our assessments.

Please note that we do not provide personal advice regarding the suitability of trading in these products.

Thunder FX does not accept retail investors unless they are able to satisfactorily answer the Appropriateness Test on our trading account web application form which addresses the following criteria:
  • Previous trading experience in financial products
  • Understanding of leverage, margins and volatility
  • Understanding of the key features of the product
  • Ability to monitor and manage the risks of trading
  • Understanding that only risk capital should be traded
OPENING COLLATERAL No While Thunder FX does not encourage trading using borrowed funds, we realize the additional funding option is appreciated by our clients.
To limit fraud risk, Thunder FX imposes a limit of $1,000 on initial account funding done via credit card, and we also limit overall credit card funding to $5,000 per month. Please note that exceptions may apply.
Thunder FX does not encourage the use of leverage products with borrowed funds. You should be aware that trading on leverage with borrowed money exposes you to greater credit risks and cash flow risks. This includes the risk of "double leverage".
Thunder FX does not accept "cash equivalents" as opening collateral (e.g. no securities as deposits).
COUNTERPARTY RISK – HEDGING Yes Within Thunder FX'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 position 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 Thunder FX.
  • The selection of hedge counterparties, in sufficient number to give reasonable assurance that Thunder FX has adequate facilities and capacity to hedge its exposures.
  • The selection and maintenance of hedge counterparty relationships based on, amongst other things, their financial capacity and resilience.
Thunder FX’s selection of hedge counterparties is based on the following factors:
  • Whether the funds placed by Thunder FX to its 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 counterparty; and
  • The services it provides and the strength of its operational controls and systems.
COUNTERPARTY RISK –
FINANCIAL RESOURCES		 Yes Thunder FX 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 Thunder FX to measure and assess its regulatory financial requirements under its international licenses.
  • Linkages between the budgetary planning process and the financial requirements.
  • Scenarios used to forecast the cash resources available to Thunder FX to meet its financial requirements; and
  • Roles and responsibilities for measuring and monitoring the financial obligation on an ongoing basis.
We do not perform regular testing of our financial needs under stress due to the fact that exposures are subject to significant variation and the results generated at any point in time may not be applicable to our financial position at other points in time. To mitigate the risks of failing to satisfy the financial requirements, we have established a capital buffer based upon historical market moves and measure and monitor capital daily. Financial resources are also subject to external audit on an annual basis.
CLIENT MONEY Yes This information is made available by Thunder FX 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 utilized by Thunder FX so that clients are better informed to assess the safety of their funds.

Client money is held with international Authorized Deposit-taking Institutions (ADIs) in compliance with regulatory requirements. Thunder FX currently holds client segregated trust accounts with top-tier banks.
Funds are not held in individual segregated accounts but are pooled with other clients' funds.Thunder FX maintains client segregated trust accounts in a number of currencies for this purpose.

Funds held in trust on behalf of a retail client may only be withdrawn by Thunder FX as permitted under applicable Client Money Rules, as set out in the Product Disclosure Statement and Client Agreement.

Funds held in trust on behalf of a wholesale client may be used by Thunder FX to meet its obligations incurred in connection with margining, guaranteeing, securing, transferring, adjusting or settling dealings in derivatives, including dealings on behalf of other clients.

A daily and a monthly reconciliation of client funds held in client segregated trust accounts is performed. On the basis of which Thunder FX either pays to or withdraws money from the segregated trust accounts reflecting the net settlement of all obligations to its clients.

We are solely entitled to any interest or earnings derived from Client Money being deposited in a trust account or invested by us in accordance with the relevant Client Money Rules, with such interest or earnings being payable to us from the relevant trust account or investment account.
SUSPENDED OR HALTED
UNDERLYING ASSETS		 Yes An underlying financial product may be placed in a trading halt on the relevant exchange in various circumstances. Additionally, it may be suspended or delisted in certain circumstances. Exchange delays depend on a number of factors including, for example, interest rates, currency supply and demand and actions of government. In some situations, exchanges or clearing houses may take action which may have an effect on transactions which relate to the underlying product.

Thunder FX, in its absolute discretion, can cancel your order in respect of a financial product that has not yet been opened, or close any open Position, where the underlying financial product is the subject of a trading halt suspension or delisting.
When you place an order for a CFD with us, it is likely that we will place a corresponding order to purchase or sell the relevant product to hedge our market risk. Thunder FX has the discretion as to when and if it will accept an order. Without limiting this discretion, it is likely that we will elect not to accept an order in circumstances where our corresponding order cannot be filled. Accordingly, Thunder FX may at any time determine, in our absolute discretion, that we will not permit the entry into a CFD over one or more underlying assets.
MARGIN CALLS Yes Thunder FX establishes minimum margin requirements for all instruments. These margin requirements are set out in the Contract Specifications available on the website.

The 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 trading application.

Where account equity falls below the total margin requirement a margin call is generated and a notification is sent to the email address provided by the client to Thunder FX. Clients are advised that it is their responsibility to ensure they maintain sufficient equity to meet the total margin requirement at all times.