Prop Firm Hub

1. MFF had Margin account with FXPig, current margin account with CDO markets
2. All live accounts (A+B book) in TGG's name
3. A book trades go to bridge then to TGG's CDO markets account
4. No live customer orders executed (tried to pin him down 4 times that they're customer orders)
5. TGG live orders from customers are 99% B book + 1% STP via TGG's CDO markets margin account
6. B book is within a virtual simulated environment hosted by iS Risk
7. Demo traders in eval are not B book
8. TGG adds slippage & delay to B book to simulate real market conditions
9. TGG marks up spread on A book feed an amount which TGG/MFF have not disclosed
10. Customers are paid from company assets
11. Stated sources of income = fees paid, security investments & A book profits
12. Some A book traders were profitable, however A book trader group were net losers most months and not profitable overall
13. Ultimate goal was to find traders that could execute in the live market
14. Was fully aware A book was not profitable via iS Risk & updates by Josh
15. Had to add capital to CDO markets account to cover margin as A book group were losing money
16. 0% of company assets & payments were from A book profits
17. 5% of company assets & payments were from financial institution investments
18. 95% of company assets & payments were from customer registration fees
19. MFF dashboard is supplied by FPFX
20. Payment tracking done via deel, crypto providers (Coinbase and later Confirmo)
21. Aware of B-booking almost all live accounts
22. B booking was the deployed strategy to preserve capital
23. Customers on B book are not counterparties to TGG since there are no deposits and their trades are not actually executed. B book trades did not exit the virtual simulated environment, so there is no counterparty on the other side.
24. Believe with help of iS risk they accurately mimic real market conditions for B book traders
25. TG/IS Risk didn't do any analysis to see if conditions on b book mimicked the real market
26. Didn't specifically disclose to customers that they were on A/B book
27. Didn't disclose payments from successful trading came from customer fees
28. Didn't disclose to customers STP/A-book group generated net trading losses
29. Worked w/ IS Risk to get B book simulated environment as close to A book as possible
30. Commissions applied & spread marked up to B book to mimic real market conditions
31. Commissions & spread mark up was recommended by IS risk and final decision was TGG
32. Agrees profitable traders on b book are cost of business expense for TGG
33. Depth of market VWAP execution was applied to all accounts April 2023 which was recommended by iS Risk to more closely mimic the real market
34. illicit trading behavior received delayed execution so they could not take advantage of MT4's deficiencies

iS Risk employee deposition...

1. TGG is counterparty to virtually all of its customers.
2. VWAP was for TGG counterparty execution
3. TGG uses VWAP to apply slippage to customer trading
4. TGG sent some trades to CDO markets
5. VWAP depth of market information is from CDO markets
6. Orders are not sent to CDO markets they are internalized by TGG
7. Some TGG customers had more delay imposed than others based on data CFTC presented
8. In most cases slippage & delay was intended to mimic the real market
9. Since there were a few risk profiles some may be more aggressive than others
10. Not aware if any analysis was done if TGG was successful at mimicking the real market
11. TGG didn't STP all customers because that would require stping their own capital overwhelmingly on losing traders
12. Not aware if any analysis was done if varying risk profiles successfully mimiced real trading
13. It depends on how each broker operates whether or not customers get the same market execution
14. Stop loss slippage settings were implemented to address MT4's issues handling gap trading
15. Execution delays were also implemented to address potential lags in price feed due to MT4 issues
16. CDO markets provides the price feed, TGG can apply whatever markups to the feed
17. TGG has control over price feed customer is shown

MFF/TGG - disgorgement cannot exceed 10M fees paid by current live accounts holders
CFTC - seeks disgorgement of 151-310M in total customer fees - 159M paid to successful customers
Court order - restraining order extended to 14th

If they get through this... Pay hefty 5-10M fine for deceptive marketing, add monthly pass fail statistics to homepage, add A/B book reality to disclaimers and contract, payout traders, reset evals in drawdown, offer 15% discount for 1-2 weeks... I think they would be back on top with FTMO in no time.