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View Full Version : New ASIC rules may limit the scope of TradeSim in Australia


David Samborsky
31st January 2004, 02:50 AM
The new ASIC rules regarding obtaining a securities license for anyone in Australia who provides financial services or products may have a serious impact on the availability our products and this website from the perspective of any local Australian residents. The following document repeated below was obtained from the ASIC website at www.asic.gov.au. Of course this won't have any effect on any overseas parties who are not governed by ASIC's laws.

I can see where they (ASIC) are coming from. To many people in Australia were being fleeced by overseas boiler rooms and so ASIC has decided to finally do something about it.

I'm just wondering whether or not a trading simulator such as TradeSim could be construed as generating buy and sell signals (in essence financial advice) as these are currently being generated by a third party package. By definition a trading simulator or backtester works on historical data so it can never give a buy or sell signal on the day but rather retrospectively. This could be a grey area that may require a lot of legal scrutiny.

What do people think?


04-013 ASIC warns 'no licence, no business'

Tuesday 20 January 2004


The Australian Securities and Investments Commission (ASIC) today provided an update on the progress of Australian financial services (AFS) licence applications under the Financial Services Reform Act (FSRA).

'ASIC now expects a substantial reduction in the final number of applicants, as a result of structural changes within the industry', ASIC Executive Director of Financial Services Regulation, Mr Ian Johnston said.

'To date, ASIC has issued over 2500 licences, with more than 1000 applications currently being assessed. We expect that the vast majority of these will receive their licence by the 10 March 2004 deadline', Mr Johnston said.

'ASIC is still expecting up to 900 applications from existing licensees and insurance brokers', he said.

ASIC is now individually contacting each one of these potential applicants, as their registration and/or licence will lapse on 11 March 2004. The FSRA prohibits financial services businesses from operating without an AFS licence from 11 March 2004. The assessment process for these applicants is relatively simple, and ASIC anticipates applications lodged before the end of January 2004 will be assessed before the 10 March 2004 deadline.

Prospective licensees who are expecting to lodge a full (i.e. non-streamlined) application for a new AFS licence, must contact ASIC urgently if they intend to continue in business after 10 March 2004. The contact at ASIC is Ms Pauline Vamos, ASIC Director of Licensing and Business Operations.

'During the two-year transition period of the FSRA, ASIC has consistently warned financial services businesses to lodge their licence applications as early as possible. We have provided extensive guidance to help industry make the transition to the new licensing regime', Mr Johnston said.

It is an offence to carry on a financial services business without a licence, punishable by a fine of $22,000 or imprisonment for two years, or both. The conduct of an unlicensed financial services business may also expose offenders to other court actions.

After 10 March 2004, ASIC will conduct surveillances targeting businesses that are illegally operating without a licence or otherwise not complying with financial services laws.

This emphasis on compliance is intended to protect the interests of consumers and uphold the integrity of the industry. ASIC will treat very seriously any individual or company that continues to operate whilst unlicensed, or fails to meet the responsibilities and obligations imposed by the reforms to the Corporations Act.

'ASIC's primary concern is to ensure that any company or individual that wishes to operate a financial services business, or provide advice in relation to a financial product, holds an AFS licence after 10 March 2004', Mr Johnston said.

'The Government has confirmed that it will not extend the transition period beyond 10 March 2004. If a business misses that deadline, they will need to have alternative arrangements in place to continue operating', he said.

For further information contact:
Ms Pauline Vamos
Director FSR - Licensing and Business Operations
Telephone: 02 9911 2178
Mobile: 0411 549 287

sectorbets
31st January 2004, 05:35 AM
As is often the case, well-meaning government regulations have unintended consquences. I've been involved with securities compliance issues in the States for over 15 years, and I can see no circumstance where a software package on its own would be deemd to produce trading recommendations. Now, if you were using the software to develop and market a trading system with performance claims and/or were producing buy/sell recommensdations, you might fall under some of the US securiteis laws, but even then the chances are remote unless you were a registered employee of a broker/dealer or investmetn advisor. Even newsletters that make direct recommendatios usually operate outside the regulations if the writer of the newletter is not registered himself.

Good luck.
Rick

Dave
12th February 2004, 02:12 AM
Surely, as you have said that Tradesim does not generate buy and sell signals for the future, but rather in the past, therfore it should be seen as a database tool ar data manipulation tool only...

hert0771
24th February 2004, 10:54 PM
I personally think in the case of TradeSim that it is not regarded as financial advice as it is not specifically giving information on individual shares.

But what about things for example like on TradersCoach.com they sell a stop loss calculator? This does not give you specific opinions regarding which share to buy or sell but it does give a recommendation as to how many or at what point should you get out (ie stop loss). There is also product here by Tony Compton called Trade Manager. This basically records your trades in a database for you and lets you know how much money you have made at the end of a specified period. It will also make a statement for you to give your accountant at the end of the year. One could argue that this is giving you feedback on previously made trades but again it is not giving specific information on individual shares. Does this constitute financial advice? I again personally do not think it does.

David Samborsky
25th February 2004, 02:29 PM
Yes technically speaking the first example may be construed as giving financial advice as to how many shares to buy, but really it is splitting hairs because the algorithm is fairly straight forward and could be coded in Excel fairly easily. Also without the trade information which really is the buy advice it is not complete.

The second example I would suggest is not giving any financial advice but rather keeping an inventory on past trades.

adetsec
13th March 2004, 04:04 PM
Sounds like a lot of academic hoo-ha to me. A lot of Public Servants with nothing better to do really. TradeSim is not and never was a program which gives financial advice in any shape or form but rather a tool for people of discretion to test their own theory/s about trding systems (using historical data). Whilst I applaud the changes to the Financial Indusrty regulations, I believe the changes were never intended to impact on programs like TradeSim which is nothing more than a "testing tool".