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Contract reading

What FULBRIGHT BULLION legally published, but does not want you to read

Every clause below is published by FULBRIGHT BULLION itself, on its own website, today. The finding is not that the text exists. It is the distance between what a client is shown and what a client agreed to. Read from its own documents on .

Contracting entity: Fulbright Bullion Limited

conflict of interestdeemed acceptancehidden feeliability waivermarketing contradictionsole discretioncomplaint deadlineno noticeunilateral amendmentwithdrawals

Fulbright Bullion tells you on its own site that it never takes the other side of your trade. Its client agreement lets it do exactly that. Commission is US$40 a side, the overnight interest rate is published nowhere, and you get 10 minutes to complain about a wrong price. At 20% of margin the firm can close your positions without telling you, and you still owe the loss.

Back to FULBRIGHT BULLION

Contract risk

Money at risk
7.5/10

Where this contract sitsHow far this contract goes, overall. Under 2 is nothing beyond the ordinary; 6 to 9 means several clauses put money you have already earned at risk; 9 and above reads as designed to make payout refusable.

0510
CriticalClauses that can cost you money you have already earned or deposited, or that remove your ability to challenge it.
6
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
19
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
17
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
4

How the 19 break downThe same flagged clauses, split by how much each one can cost you. Severity is our reading of the clause, not the broker's label.

Critical6
Warning10
Notice3

The numbers in this contractFigures taken from this broker's own clauses, so the labels differ from broker to broker. The four in the panel above are the same on every report.

2 of these 4 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

Critical20%Account limit. Jump to the clause this comes from.Positions closed at 20% of margin with no warningCritical10Time to complain. Jump to the clause this comes from.Ten minutes to complain about a wrong price$40Fee you were not shown. Jump to the clause this comes from.US$40 a side, and a charge list the dealer fills in later90 daysDocument deadline. Jump to the clause this comes from.Data promised to stay put, and terms that send it abroad

What the documents say

19 clauses worth knowing about, worst first, each quoted from FULBRIGHT BULLION's own files

01

Fulbright Bullion's company pages promise, in both Chinese scripts, that it never takes the other side of your trade. Clause 8.1 of the client agreement entitles it to do exactly that, by itself or through its staff.

In plain words

On a principal basis, as your counterparty, means the broker takes the other side of your trade itself. Your loss is then the firm’s gain, so it has an interest in how your trade ends.

Why this matters

When the firm holds the opposite position, your loss is its gain. You chose this broker on a page that told you that cannot happen, and the contract you signed says it can.

Exhibit 1CriticalStandard wording

The Dealer is entitled to by itself or its agents or staff take opposite position to match open position of the Client.
Clause 8.1 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.12
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must tell a retail client before they trade when the firm is the counterparty to their trades, and must manage that conflict. This contract allows the firm to take the opposite side, while its public page says it never does.

FULBRIGHT BULLION is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 7The firm can be on the other side of your trade and its own quote is the price you agreed to treat as the best available.
02

Once your balance falls to 20% of the margin on your positions, Fulbright Bullion can close any or all of your contracts without telling you first and without asking. You then owe whatever loss is left.

In plain words

Negative balance protection is a limit that stops you owing more than you put in. Without it, one fast market move can leave you owing the broker money on top of your deposit.

Why this matters

Gold margin is US$2,500 a contract, so US$500 left in the account is enough to trigger a forced close. If the market gaps after a weekend, the shortfall is a debt you have to pay.

Exhibit 2CriticalHarder than usual20%

當戶口結餘少於基本按金的20%或以下，本公司有權在不事先知會客戶或未經客戶同意下，將客戶戶口內任何及部分或全部合約平倉。
Clause 6 in 黃金客戶開戶須知, p.2
Downloaded from the broker's site on Open the reference

What it costsOne gold contract needs US$2,500 of margin. At US$500 left, which is 20% of it, Fulbright Bullion can close the position before you hear from anyone.

Set against a regulated standard: ESMA (EU), FCA (UK)

Retail clients of firms under ESMA and FCA rules get negative balance protection, so a loss cannot exceed the money in the account. This contract makes you liable for the whole shortfall, including a gap at the next opening.

FULBRIGHT BULLION is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Balance under 60% of marginYou are asked to top the account back up to the full margin.6
Balance at or under 20% of marginFulbright Bullion can close any or all of your contracts without notice or consent.6
After the close outYou owe every loss left in the account, including the full loss from a gap at the next opening.6
  • Worse together with Exhibit 7The balance that triggers the close out is measured against prices the firm itself sets.
03

If the trading system shows a wrong price, you have 10 minutes to complain. After that Fulbright Bullion says it will not accept the complaint, and its own rules decide what the price should have been.

Why this matters

A bad fill you notice at lunchtime is already out of time. You cannot challenge the price, and the firm that quoted it is the one that rules on it.

Exhibit 3CriticalRarely seen10

如有錯價，一切依本公司之規定爲準。此外，客戶必須在系統錯價10分鐘內提出投訴，否則將不予接納。
Clause 14 in 黃金客戶開戶須知, p.4
Downloaded from the broker's site on Open the reference

Our readingA complaint deadline measured in minutes is not something a retail contract normally contains. Disputes about a wrong price are usually handled under a complaints procedure with a window of weeks or months.

  • Worse together with Exhibit 5One clause closes the door on a wrong price in minutes, the other closes it on the whole month's statement in seven working days.
04

The tax addendum lets Fulbright Bullion deduct from or hold back part of any amount payable to you, and close your account, whenever it thinks that is necessary or desirable for tax compliance. No ceiling and no notice period are stated.

Why this matters

Your withdrawal can come back short, and the clause gives you nothing to measure the deduction against. The same addendum warns that a closure it forces may pay you less than closing the account yourself.

Exhibit 4CriticalHarder than usual

The Client agrees that FBL and/or its Affiliates may take one or more of the following actions at any time if it considers necessary or desirable to comply with all Applicable Laws and Regulations: (a) deduct from or withhold part of any amounts payable to the Client under the Account;
Clause Tax and CRS Addendum 8(a) in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.33
Read from the broker's site on Archived copyOpen the reference
  • Worse together with Exhibit 18The same addendum sets a document deadline and then attaches a money consequence to missing it.
05

You have seven working days to object in writing to a monthly statement. Miss that and the statement binds you, even though the contract treats a notice as delivered when it is posted, whether it reaches you or not.

Why this matters

A trade you never authorised becomes final once the clock runs out. In any dispute after that, copies of the firm's own trading records are agreed to be conclusive proof of what happened.

Exhibit 5CriticalHarder than usual7 working days

The statements shall be deemed to be accepted and have binding effect if not objected to in writing by the Client directed to the address stated therein (or such other address communicated in writing by the Dealer) within seven (7) working days after the transmittal thereof to the Client, by mail, telex, email or otherwise.
Clause 14.3 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.17
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK)

Firms licensed by the FCA must run a published complaints procedure and tell clients they can take an unresolved complaint to an independent ombudsman. This agreement names no complaints procedure and treats a statement as accepted after seven working days.

FULBRIGHT BULLION is not licensed by this regulator, so this is a comparison of practice, not a finding of any breach.

06

You can appoint someone to run your account with full power, and the contract says that person is your agent even when Fulbright Bullion employs them. The firm then takes no responsibility for anything that person does.

Why this matters

If a member of staff trades your account and loses your money, the contract points at them, not at the firm that pays them. The account opening notice separately tells you brokers are barred from operating client accounts, so the two documents do not line up.

Exhibit 6CriticalRarely seen

It is expressly agreed by the Client that the Authorized Agent is the agent of Client despite the fact that such Authorized Agent may be employed by the Dealer.
Clause 5.4 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.8
Read from the broker's site on Archived copyOpen the reference

Our readingLetting a member of the firm's own staff hold a power to trade your account, while the contract calls that person your agent and not the firm's, puts one person on both sides and leaves nobody for you to hold responsible.

Fulbright Bullion denies in public what its contract permits

Two promises on Fulbright Bullion's own pages do not survive the client agreement. The company page says it never takes the other side of your trade, and clause 8.1 entitles it to do so through itself or its staff. The business page offers professional investment advice, and clause 4.2 says nothing the firm gives you is advice, an opinion or a recommendation.

Public claim, private clause1 clause flagged

The business page offers you professional investment advisory services. Clause 4.1 of the agreement says no officer, agent or member of staff is authorised to give advice, and that anything you are told is a personal opinion.

Why this matters

Act on what a Fulbright Bullion adviser tells you and the loss is yours. Clause 4.1 also has you agree not to hold that person, or the firm, liable for it.

Exhibit 8WarningHarder than usual

In any event, the Client shall not hold the person giving the advice, the Dealer or any other person liable for any loss resulting from the Clients reliance upon such advice.
Clause 4.1 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.5
Read from the broker's site on Archived copyOpen the reference

US$40 a side is the only charge Fulbright Bullion actually publishes

Commission is US$40 for each side of a contract and US$80 for a round turn, and the firm's own notice calls it negotiable. Clause 15.1 adds interest, a custodian fee on overnight positions, storage, insurance and miscellaneous charges at rates Fulbright Bullion sets from time to time, and no schedule of them is published. The overnight interest rate is in no document at all: the examples page tells you to telephone and ask.

Cost disclosure3 clauses flagged

Commission is US$40 for each side of a contract, US$80 to open and close, and the firm's own notice calls the figure negotiable. Clause 15.1 adds interest, a custodian fee on overnight positions, storage, insurance and miscellaneous charges, all at rates Fulbright Bullion sets from time to time.

Why this matters

You cannot total up what trading here costs, because no schedule of those charges is published anywhere. The service page says fees can change with no notice to you, and tells you to watch a page that carries one posting, from March 2023.

Exhibit 9WarningHarder than usual$40

每張單邊買賣合約為美元$40（一套美元$80）（可面議）。
Clause 7 in 黃金客戶開戶須知, p.2
Downloaded from the broker's site on Open the reference

What it costsOne gold contract costs US$80 in commission to open and close. The usual 50 cent spread on 100 ounces adds about US$50, so a round turn starts near US$130.

Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must disclose costs and charges to a retail client before they trade. This agreement lets the firm set commission, interest, custodian, storage and insurance charges from time to time, and publishes no schedule of them.

FULBRIGHT BULLION is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

  • Worse together with Exhibit 10The charges you can see are negotiable per client and the one you cannot see is set by telephone.

Hold a position overnight and Fulbright Bullion charges or pays interest until you close it. The rate is in no document: the examples page tells you to telephone a member of staff to find out what it is.

Why this matters

A cost you cannot look up is a cost you cannot plan for. The account opening notice says a short seller receives interest, while the worked example on the site charges the short seller and takes it out of the profit.

Exhibit 10WarningHarder than usual

注：利率會隨市況而波動，具體利率請向富昌金業的職員查詢。
Clause 交易例證 in 交易例證
Read from the broker's site on Open the reference

The physical gold page offers an overdraft against bars you bought, interest free and fee free, up to 70% of the gold price. Clause 15.2 charges any debit balance at 3% above HSBC's prime rate, worked out daily.

Why this matters

No separate terms for that overdraft are published, so the only published rate that can apply to the money you owe is the one in clause 15.2. Borrowing against your bars to fund margin also puts the bars behind the firm's lien.

Exhibit 11WarningHarder than usual3%

The interest will be charged at the rate of 3% per annum above the prime lending rate quoted by the Hong Kong and Shanghai Banking Corporation Limited for the time being in force calculated on a daily simple basis.
Clause 15.2 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.18
Read from the broker's site on Archived copyOpen the reference
Our own capture of fbgold.com.hk, taken on Oct 16, 2026The claim, on Physical gold products page, paragraph on pledging purchased barsVisit this page on the broker's siteDownload the full size image file

Your positions can go at 20% of margin, and the contract arrives later

At 20% of margin Fulbright Bullion can close any or all of your contracts without notice and without your consent, and you owe whatever loss is left. The client agreement that sets those terms is posted to you within seven working days after the account is already open. Online trading adds that every instruction entered with your password is treated as yours.

Account control2 clauses flagged

Fulbright Bullion posts the client agreement to you within seven working days after your account has been opened. If you do not accept what it says, the remedy it offers is closing the account.

Why this matters

The online form asks you to agree to a client declaration, a tax exchange notice and a FATCA statement, and the client agreement is not among them. One of those three links opens a web page instead of the document.

Exhibit 15WarningHarder than usual7 working days

客戶協議書將於帳戶開立後，七個工作天內連同開戶表格副本和開戶協議書郵寄給閣下。如不接納該協議書內容，可隨時聯絡我們取消戶口。
Clause 注意 in 開戶步驟
Read from the broker's site on Open the reference
  • Worse together with Exhibit 14The document that governs arrives after you have joined, and the version that decides a dispute is in a language the site never uses.

The internet trading terms make you solely responsible for every instruction entered with your customer ID and password. The same terms say Fulbright Bullion is not responsible for unauthorised use of your access numbers, passwords or account numbers.

Why this matters

If someone else gets into your account and trades it, the trades are treated as yours. The firm can also cut off your access at its sole discretion, without notice and for any reason.

Exhibit 16WarningHarder than usual

the Client shall be solely responsible for all Instructions entered through the Internet Trading Service using its Customer ID and Password and any Instructions so received by the Company shall be deemed to be made by the Client at the time received by the Company and in the form received;
Clause Internet Trading Agreement 2.3(iv) in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.22
Read from the broker's site on Archived copyOpen the reference

Ten minutes for a wrong price, seven working days for a statement

Fulbright Bullion gives you 10 minutes to complain about a system price error, after which the account opening notice says the complaint will not be accepted. A monthly statement is deemed accepted after seven working days, and the firm's own trading records are agreed to be conclusive proof in any dispute. Its website disclaimer asks every visitor to release the company and its staff from claims simply for entering the site.

Time to object1 clause flagged

The disclaimer says that on entering the site, each user releases Fulbright Bullion, its related companies, directors, officers, staff and agents from any claim and any proceedings over loss or damage.

Why this matters

A release that broad is triggered by reading the page, not by trading. The same page says the firm may change those terms whenever it likes, and describes the change as being for your protection.

Exhibit 17WarningRarely seen

進入本網頁後，每個使用者將對富昌金業有限公司及其所有有關公司及其個別董事、高級人員、職員、代理人的責任，免除任何索償及有關損失、虧損或後果的任何程序。
Clause 任何使用本網頁 in 免責聲明
Read from the broker's site on Open the reference

Our readingMost website terms limit liability for the content of the page. This one asks a visitor to give up claims and proceedings against the company and its people as a condition of arriving.

Hong Kong law, a Shenzhen court for mainland clients, an English text that wins

Fulbright Bullion publishes two versions of one agreement. The mainland version keeps Hong Kong law but sends disputes to the people's court for the place of signing, and fixes that place as Futian District, Shenzhen. Both versions say the English text prevails over the Chinese, on a site that is published only in Chinese.

Where you would sue2 clauses flagged

Fulbright Bullion publishes two versions of the same agreement. The one for mainland clients keeps Hong Kong law but sends a dispute to the people's court where the agreement was signed, and fixes that place as Futian District, Shenzhen.

Why this matters

You may never have been to Futian, and the contract decides for you that you signed there. A mainland court would then be asked to apply Hong Kong law to a Hong Kong firm's contract.

Exhibit 13WarningRarely seen

In case such attempt fails, any Party to this Agreement may apply to the people's court where the agreement has been signed. The place of signing of agreement is Futian District, Shenzhen, Guangdong Province, China.
Clause 18.8 in 金業客戶協議書（國內客戶）Bullion Client's Agreement (China clients)
Read from the broker's site on Open the reference

Our readingTwo versions of one retail agreement with different dispute clauses is unusual, and a deemed place of signing in a named district the client may never have visited is more unusual still.

  • Worse together with Exhibit 14A mainland client is pointed at a Shenzhen court to argue about an English text they were never sold in.

Every page Fulbright Bullion publishes is in traditional or simplified Chinese. Clause 18.9 says that where the English and Chinese versions of the agreement differ, the English version prevails.

Why this matters

The text that decides a dispute is the one you were never marketed in. The internet trading terms and the data statement carry the same rule.

Exhibit 14NoticeStandard wording

If there is a discrepancy between the English and Chinese versions of this Agreement, the English version shall prevail.
Clause 18.9 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.20
Read from the broker's site on Archived copyOpen the reference

The promise not to share your data is on a different page from the terms

Fulbright Bullion's disclaimer says it will not disclose client data to any other organisation without clear consent. The data statement inside the client agreement transfers it to the mainland and overseas unless you opt out in writing, and says protection there may be weaker. The tax addendum gives you 90 days to produce documents on request.

Your data1 clause flagged

The disclaimer says Fulbright Bullion will not disclose your data to any other organisation without your clear consent. The data statement in the agreement moves it to the mainland and overseas unless you opt out, and warns protection there may be weaker.

Why this matters

Opting out is on you, in writing, after you have handed the data over. The tax addendum also gives you 90 days to produce documents, and names a different group company, Fulbright Securities Limited, as the one to send them to.

Exhibit 18WarningStandard wording90 days

如沒有客人清楚同意或除法律規定外，我們將不會披露客人的資料予任何其他機構。
Clause 私隱政策及互聯網保安 in 免責聲明
Read from the broker's site on Open the reference

The dealer can hold your position, employ your agent and set your price

Clause 8.1 lets Fulbright Bullion take the opposite position to yours. Clause 5.4 lets one of its own employees hold full power over your account as your agent, with the firm not responsible for what that person does. Clause 8.3 has you accept that the price the dealer offers is the best price then available, and no outside benchmark appears anywhere in the contract.

Both sides of the trade1 clause flagged

Clause 8.3 has you accept that whatever price Fulbright Bullion offers you is the best price then available. The home page adds that all prices are settled by the firm's own dealing room.

Why this matters

There is no outside benchmark in the contract to measure a fill against. Having agreed the price was the best one going, you have given away the argument before you start it.

Exhibit 7WarningHarder than usual

Thus the Client agrees to accept that such prices as the Dealer may offer him from time to time are the best prices then available.
Clause 8.3 in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.12
Read from the broker's site on Archived copyOpen the reference

Fulbright Bullion pays the same day it promises, within four days it owes

Clause 8.7 of the Fulbright Bullion agreement commits to paying a withdrawal within 4 days, while the service page promises a crossed cheque the same day. The tax addendum sits over both: it lets the firm deduct from or hold back part of any amount payable to you whenever it considers that necessary or desirable, with no ceiling stated.

Exit conditions1 clause flagged

The service page promises that every withdrawal goes out the same day by crossed cheque, a cheque that can only be paid into a bank account. Clause 8.7 of the agreement only commits Fulbright Bullion to paying you within 4 days.

Why this matters

The fast promise is the one on the page you read, and the slow one is the only one you can enforce. Instructions after 2:00 pm are handled the next day, and payment goes to a bank account in your own name.

Exhibit 12NoticeStandard wording4 days

所有提取款項均於提款指示發出當日以劃線支票發出予客戶。
Clause 提款方法 in 交收及存款方法
Read from the broker's site on Open the reference

Fulbright Bullion Limited, with no segregation clause in its contract

You contract with Fulbright Bullion Limited of Kowloon Bay, which the agreement calls the Dealer and which may act as principal or as your agent. Client money is paid into bank accounts titled as client accounts at three named banks, but the agreement contains no promise to hold client money separately and names no compensation scheme. It sets out no complaints procedure either.

Who you contract with1 clause flagged

Your money goes to bank accounts titled as client accounts at three named banks. The agreement itself contains no promise to hold client money separately, names no compensation scheme and sets out no complaints procedure.

Why this matters

If Fulbright Bullion fails, nothing in the contract tells you where your balance sits or who makes you whole. The agreement also lets the firm take any credit balance of yours to cover a debit balance, without calling you first.

Exhibit 19NoticeStandard wording

Fulbright Bullion Limited (hereinafter referred to as Dealer), whose registered office is situated at Room 20, 9/F, Tower III, Enterprise Square, No.9 Sheung Yuet Road, Kowloon Bay, Hong Kong
Clause Parties in 金業客戶協議書 Bullion Client's Agreement (Hong Kong and other clients), p.2
Read from the broker's site on Archived copyOpen the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA and CySEC must hold retail client money in segregated accounts and belong to a compensation scheme that pays out if the firm fails. This agreement has no segregation clause and names no scheme.

FULBRIGHT BULLION is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

Where the marketing and the contract disagree

A promise made in public, set against the clause that governs it

01

The public page says the firm never takes the other side of a client trade, and clause 8.1 entitles it to do so.

Said in public, in Chinese

本公司絕不對賭，投資者可放心交易。

Word for word in English: This company absolutely never takes the other side of the bet, investors can trade with peace of mind.

Company introduction page, repeated word for word on the simplified Chinese page for mainland investors

In the contract · clause 8.1

The Dealer is entitled to by itself or its agents or staff take opposite position to match open position of the Client.

02

The page promises prices in line with the exchanges and no deviation, while the contract has you accept the dealer's own quote as the best price available.

Said in public, in Chinese

客戶買賣黃金及白銀價格與各大交易所看齊，更與花旗、匯豐、JP Morgan等大行享有同等的交易地位，不會有價格偏差。

Word for word in English: Clients buy and sell gold and silver at prices in line with the major exchanges, and enjoy the same trading status as large houses such as Citibank, HSBC and JP Morgan, with no price deviation.

Company introduction page, paragraph on the quotation systems used

In the contract · clause 8.3

Thus the Client agrees to accept that such prices as the Dealer may offer him from time to time are the best prices then available.

03

Professional investment advice is offered on the business page and disclaimed in clause 4.2 of the agreement.

Said in public, in Chinese

富昌金業專注為客戶提供本地黃金/白銀買賣服務，實物黃金買賣業務，以及為投資者提供專業的投資顧問服務。

Word for word in English: Fulbright Bullion concentrates on providing clients with local gold and silver trading services, physical gold trading, and professional investment advisory services for investors.

Business introduction page, opening paragraph

In the contract · clause 4.2

Client further acknowledges that any investment research reports or other data provided by the Dealer, its agents, officers or staff does not constitute any advice, opinion or recommendation.

04

An interest free overdraft is advertised against purchased gold bars, while the only published rate on a debit balance is 3% over HSBC prime.

Said in public, in Chinese

該透支服務免息，免手續費，透支額更可高達金價的70%，方便客戶靈活調配資金。

Word for word in English: This overdraft service is interest free and handling fee free, and the overdraft can be as high as 70% of the gold price, so clients can move funds around flexibly.

Physical gold products page, paragraph on pledging purchased bars

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of fbgold.com.hk

In the contract · clause 15.2

The interest will be charged at the rate of 3% per annum above the prime lending rate quoted by the Hong Kong and Shanghai Banking Corporation Limited for the time being in force calculated on a daily simple basis.

The documents this reading is based on

17 files, all published by FULBRIGHT BULLION. Each shows when we read it and a fingerprint of its wording.

WIKILIX keeps the copy of each file it read, and does not republish it: what is published is the fingerprint of its wording. Download the file yourself and hash its text, lowercased with runs of whitespace collapsed, and a matching fingerprint means the wording quoted above is still the wording FULBRIGHT BULLION publishes.

How this reading was done

Every clause above was read out of a document FULBRIGHT BULLION publishes itself

This reading was published on .

Documents
8 of 17downloaded from the broker's site, and 8 read in full
Pages opened
22pages walked to find those documents, footer links included
Marketing pages
8public pages set against what the contract says
Languages
EN vs ZH-HKthe language it advertises in, against the language it contracts in

Who the contract is with

Fulbright Bullion Limited

You contract with Fulbright Bullion Limited, at Room 20, 9/F, Tower III, Enterprise Square, No.9 Sheung Yuet Road, Kowloon Bay, Hong Kong. The agreement calls it the Dealer and lets it act either as principal or as your agent. The tax addendum puts it in a group with Fulbright Securities Limited and Fulbright Futures Limited. The data statement names eight further Fulbright companies. The disclaimer page on the same site gives a different address, in Central.

Quotations are copied verbatim from the documents named above, with the clause number and the page each one came from. Where a clause is quoted in another language, the original is shown first and the English is a translation.

The plain-language parts, what a clause means for a client, how ordinary it is, and how it reads against a regulated standard, are WIKILIX's analysis and are labelled as such on every card. This is a reading of public documents, not legal advice and not an allegation of wrongdoing.

In fairness, and what we could not check

A reader who knows the edges of the work can trust the middle of it

Fulbright Bullion publishes what many bullion dealers keep private. The margin per contract, the commission and the trading hours are all set out. Client money goes to three named bank accounts, each titled as a client account. No document we read contains an inactivity fee, a dormancy ladder or a bonus scheme. Withdrawal instructions given before 2:00 pm are paid the same day by crossed cheque, which is faster than most. Clause 18.2 also stops the firm rewriting the main agreement on its own.

We could not open the client declaration that online applicants must accept, so we did not read it. The FATCA declaration linked from the same online form opens a web page instead of the document. We did not read the self certification form, the FATCA form, the standalone personal data statement or the change of information form. We also did not read the withdrawal form, and we read only part of the telegraphic transfer form and part of the account opening form. The two certificates on the licences page are published as pictures, so their wording could not be read. Quotations from the two client agreements are taken from the English text, which the agreement itself says prevails. No earlier version of any of these documents is available, so this is a first reading with nothing to compare against.

How to check any of this yourself

Every quote above links to the FULBRIGHT BULLION file it came from. This is what to do with it.

Open the three stepsFind the words in the source, work out the fingerprint, and read what a difference does and does not prove.

Open the source and search for the words

Every quote has a link under it. Open the file, or the web page, and search it for the words we quote. The clause number next to the quote tells you where to look.

If the words are not there any more, the source may have changed after we read it. That is worth knowing too. We keep the date we read it, and a code worked out from its wording, so the quote stays checkable.

What a fingerprint is

A fingerprint is a code worked out from what a source says. Change one word and the code changes completely. We keep two codes for every file we read, and the panel on each source shows both.

The first is the code of the exact file we downloaded. The second is the code of its wording alone, with capital letters lowered and runs of spaces collapsed. When the same words are saved as a new file, the first code changes and the second one stays the same.

Only the first code can be worked out on your own computer. Save the file, then run one of these, putting the name of the file you saved where the example is. The panel on each source prints the command with that source's real file name already in it.

macOS or Linux:
  shasum -a 256 the-file-you-saved.pdf

Windows:
  certutil -hashfile the-file-you-saved.pdf SHA256

The two codes are different from each other, and they are not meant to match. Comparing one against the other proves nothing.

What a difference means, and what it does not

A different file code on its own proves nothing. A PDF saved again with a new date inside it is a new file saying exactly the same thing.

A different wording code means the words themselves changed. That is the one that matters, and it is why we keep it.

Even then, a change is not proof of bad faith. Companies update their documents. What this report says is what the document said on the day we read it, and every quote carries that date.

A source that is a web page and not a file has no file to save, so only the code of its wording is shown.

How this report is made

Every clause quoted above comes from a document FULBRIGHT BULLION publishes on its own website, downloaded and hashed on the date shown, with the clause number and page recorded so any reader can check it. We do not allege anything the documents do not say, and we do not judge FULBRIGHT BULLION on anything other than its own published terms and its own public marketing. Where a clause has a qualifier that softens it, the report says so. Last read Oct 16, 2026.

If you represent FULBRIGHT BULLION and a clause has changed, been withdrawn, or is being read out of context, tell us and we will re-read the documents and update this page. Corrections from the broker are welcome and are published with the reading they change. Contact us.

This is a reading of a contract, not legal advice and not a ruling on FULBRIGHT BULLION. Whether its licence is real and current is a separate check on the broker profile.

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