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Contract reading

What Gungin legally published, but does not want you to read

Every clause below is published by Gungin 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: ぐんぎん証券株式会社 (Gungin Securities Co., Ltd.)

hidden feewithdrawalswrap accountcost disclosureaccount accessaccount restrictionsagencycompensation schemecomplaintsconflict of interest

Gungin publishes its contract as 16 PDF chapters whose text cannot be read, so its withdrawal and amendment clauses stayed unchecked. The fund wrap costs 1.320% a year in advisory fees, plus up to 1.50% inside the funds, and Gungin says the total cannot be shown. On foreign shares Gungin can be the other side of your trade at 2.5% from mid price, each way. Withdrawals cost you an unstated fee unless they go to a Gunma Bank account.

Back to Gungin

Contract risk

Harder than average
4.5/10

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.
0
FlaggedEvery clause worth knowing about, at all three severities. Ordinary terms that every broker has are not counted.
16
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
47
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
2

How the 16 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.

Critical0
Warning11
Notice5

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.

1.32%Fee you were not shown. Jump to the clause this comes from.Fund wrap fees stack and the total is not published2.5%In the contract. Jump to the clause this comes from.Gungin takes the other side of foreign share trades10%Account limit. Jump to the clause this comes from.Only one tenth of new share allocations is balloted3 working daysWithdrawal limit. Jump to the clause this comes from.Fund wrap exit takes weeks and has no cooling off

What the documents say

16 clauses worth knowing about, worst first, each quoted from Gungin's own files

01

You pay Gungin 1.320% a year on the first ¥20,000,000 of a Master Program fund wrap. The funds it buys take up to 1.50% a year on top, and Gungin's own page says the total cannot be written down.

Why this matters

On a ¥3,000,000 contract the two layers alone can reach about ¥84,600 in the first year. You cannot check that figure against another broker, because Gungin publishes no total.

Exhibit 1WarningHarder than usual1.32%

当サービスでは、下記に定める計算期間、計算基準額に応じた投資顧問報酬をお支払いただきます。
Clause ファンドラップの費用 in ファンドラップ
Read from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026Fund wrap fees stack and the total is not published (clause ファンドラップの費用)Visit this page on the broker's siteDownload the full size image file

What it costsA ¥3,000,000 Master Program contract pays ¥39,600 a year in advisory fees at 1.320%. Up to ¥45,000 more comes out inside the funds at 1.50%.

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

Firms licensed by the FCA, and firms under ESMA rules, must give a retail client the total costs and charges of a service before they invest, in cash as well as in percentages. Gungin's fund wrap page states that the total and the upper limit cannot be given.

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

  • Worse together with Exhibit 14A cost you cannot total sits on a contract you cannot leave quickly and cannot cancel in a cooling off period.
02

Gungin reports that it explains the approximate real cost of a fund wrap when it proposes one to you. That same cost total is the thing its public fund wrap page says it cannot state.

Why this matters

You can only get the number by sitting down with a salesperson. Comparing Gungin's fund wrap against another firm's before you make contact is not possible from the published pages.

Exhibit 2WarningHarder than usual

ファンドラップを提案する際、「重要情報シート」によりお客さまが負担する実質的な費用概算を説明しています。
Clause 3（3）手数料等の透明性向上 in 「お客さま本位の業務運営」の取組状況, p.11
Downloaded from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026What the contract says, clause 投資信託に係る費用Visit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA or CySEC must provide costs and charges information in good time before a retail client is bound, not only inside a sales meeting. Gungin's published page says the total cannot be given, while its own progress report says the figure is explained at the proposal stage.

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

03

Buy a US share through Gungin's domestic over the counter route and Gungin is the seller. It prices your trade 2.5% away from the mid price, then tells you it charges no separate commission.

Why this matters

Buying and selling the same share costs you about 5% before the price moves at all. Gungin sets the spread it earns, and it holds the stock you trade against.

Exhibit 3WarningHarder than usual2.5%

お客さまからのご注文に対して、ぐんぎん証券が相手方となって売買を成立させる方法（相対取引）です。
Clause 外国株式 / 国内店頭取引 in 商品のご案内 株式、ETF、REIT
Read from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026Gungin takes the other side of foreign share trades (clause 外国株式 / 国内店頭取引)Visit this page on the broker's siteDownload the full size image file

What it costsA ¥1,000,000 purchase carries about ¥25,000 of markup inside the price. Selling it back at the same mid price costs about ¥25,000 again.

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

Firms licensed by the FCA or CySEC must tell a client when they deal on their own account against that client, and manage the conflict. Gungin's best execution policy rules out principal dealing for Tokyo listed shares, and its conflict of interest summary does not mention the foreign share route.

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

04

Send your money to a Gunma Bank account and Gungin pays the transfer fee. Send it anywhere else and you pay a fee that Gungin's fee page never puts a number on.

Why this matters

You cannot work out the cost of taking your money out before you ask for it. Deposits are free from any bank, so the charge falls only on the way out.

Exhibit 4WarningHarder than usual

所定の手数料をご負担いただきます。
Clause 6．振込手数料（2）証券取引口座からお客さまへの振込 in 手数料について
Read from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026Free withdrawals only to the parent bank (clause 6．振込手数料)Visit this page on the broker's siteDownload the full size image file
05

Gungin refunds the transfer fee your old broker charged you, up to the full amount. Moving the same holdings out of Gungin later costs you ¥1,100 for one trading unit, rising to ¥11,000 at 19 units.

Why this matters

Leaving Gungin with a 19 unit holding costs you ¥11,000 per issue. The refund that brought you in can be changed or stopped without notice, and clients who opened through a Gunma Bank branch never qualified for it.

Exhibit 6WarningHarder than usual

1単元以下・・・・・・・1,100円
Clause 4．証券の預替え（移管）手数料（税込） in 手数料について
Read from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026Transfers in are refunded, transfers out are charged (clause キャッシュバック金額)Visit this page on the broker's siteDownload the full size image file
  • Worse together with Exhibit 4Both charges fall on the way out, so moving your holdings and then moving the cash each carry a fee.

Your money leaves free only if it goes to Gunma Bank

Gungin pays the transfer fee on a withdrawal to a Gunma Bank account and charges an unstated fee to any other bank. Its two published cut-off times for same day processing differ by half an hour, 4pm on one page and 3:30pm on another. Cancelling a fund wrap takes three business days plus about two to three weeks.

Getting money out2 clauses flagged

Gungin's deposit and withdrawal page tells you to call by 4pm for payment the next business day. Its online service leaflet sets the same cut-off at 3:30pm.

Why this matters

Ask at 3:45pm through the online service and your money arrives a business day later than the other page promised. A weekend request is only received the next business day, then paid the day after that.

Exhibit 5WarningHarder than usual

お客さまからぐんぎん証券に、午後4時までにご連絡いただいた場合は、原則として翌営業日に登録預金口座にお振込みいたします。
Clause ご出金について in 入出金について
Read from the broker's site on Open the reference
Our own capture of gunginsec.co.jp, taken on Oct 10, 2026The claim, on Gungin's deposit and withdrawal page, under the heading on withdrawalsVisit this page on the broker's siteDownload the full size image file

Cancel a Gungin fund wrap and the cancellation takes effect on the third business day. The money reaches your securities account about two to three weeks after that, and no cooling off right applies.

Why this matters

You are out of the market and out of your cash for most of a month. There is no short window after signing in which you can change your mind.

Exhibit 14WarningHarder than usual3 working days

当サービスにはクーリング・オフ制度が適用されません。
Clause ご留意事項 in ファンドラップ
Read from the broker's site on Open the reference

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Request acceptedGungin accepts your cancellation at a branch counter.解約
3rd business dayThat day becomes the cancellation date, and redemption of the dedicated funds starts.解約
About 2 to 3 weeks laterThe cash reaches your Gungin securities account, not your bank.解約
  • Only applies after Exhibit 4The cash lands in your securities account, so a further withdrawal and its unstated fee stand between you and your bank.

Gungin's online service trades funds only, by full prepayment

Gungin's online service handles domestic investment trusts and nothing else, and wants the full purchase amount on deposit first. Every share, bond and foreign share order goes through a salesperson or a branch phone call. Only 10% of new share allocations are balloted, with the rest at Gungin's judgement.

What you can actually do2 clauses flagged

Gungin puts 10% of the shares it sets aside for individuals into a ballot. It hands out the other 90% at its own judgement, weighing how much you hold and how much you trade.

Why this matters

Your chance of an allocation rises with the size of your account, not with luck. Gungin caps you at four allocations a year and never tells you when you have lost a ballot.

Exhibit 13WarningHarder than usual10%

この場合、当社が配分する数量のうち、個人のお客さまへの配分予定数量の 10％を当該抽選に付すことといたします。
Clause 3（1）Ａ in 募集等に係る株券等の顧客への配分に係る基本方針, p.2
Downloaded from the broker's site on Open the reference

Gungin's online service buys and sells domestic investment trusts, and that is all it trades. Shares, ETFs, REITs, bonds and foreign shares go through a salesperson or a phone call to your branch.

Why this matters

You cannot place a share order yourself at any hour, and you must deposit the full purchase amount before you can order online. Company accounts get no trading access at all, only enquiries.

Exhibit 12NoticeHarder than usual

投資信託のお取引や各種照会等ができるインターネットサービスです。
Clause 「ぐんぎん証券オンラインサービス」の概要 in ぐんぎん証券オンラインサービス サービスのご案内
Read from the broker's site on Open the reference

Fund wrap complaints have nowhere outside Gungin to go

Gungin's complaints table sends securities complaints to FINMAC and fund wrap disputes to the Gunma Bar Association centre. Against complaints for the fund wrap it prints a dash. Its site policy separately refuses all responsibility for losses caused by the website's content.

If it goes wrong2 clauses flagged

Complain about Gungin's securities business and FINMAC, the national securities ombudsman, takes both complaints and disputes. For the fund wrap, Gungin's table offers only the Gunma Bar Association centre, and marks it as handling disputes, not complaints.

Why this matters

A fund wrap grievance that is not yet a formal dispute has nowhere outside Gungin to go. The one external body sits in Maebashi and answers the phone on weekdays from 10am to 5pm.

Exhibit 7WarningStandard wording

特定投資助言・代理業務（ファンドラップに関する業務）に関しては、群馬弁護士会との協定書に基づき、同弁護士会紛争解決センターにおいて、指定紛争解決機関と同様の和解あっせん手続きを行っています。
Clause 2（1）②指定紛争解決機関が存在しない場合の措置 in 苦情処理・紛争解決に係る業務運営体制, p.1
Downloaded from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA give retail clients free access to the Financial Ombudsman Service for complaints as well as for disputes. Gungin's table routes fund wrap complaints nowhere outside the firm, and sends disputes to a regional bar association centre.

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

Gungin's site policy says it accepts no responsibility at all if the website's content causes you a loss. The same document recommends Internet Explorer 9, 10 and 11, and Windows 7.

Why this matters

The browsers that document recommends cannot register a passkey, and Gungin has required a passkey for online trading and withdrawals since May 2026. A document this far out of date is a poor place to rest a blanket disclaimer.

Exhibit 8NoticeStandard wording

万一、当ホームページの内容に基づいて何らかの損害を被った場合でも、当社および情報提供元の第三者は一切の責任を負いかねます。
Clause 免責について in サイトポリシー, p.1
Downloaded from the broker's site on Open the reference

A passkey is now compulsory and getting one can lock you out

Gungin has required a passkey for online fund trades and withdrawals since May 2026. Registering one without a Our Number card resets both your passwords and blocks every login until a registered letter arrives, with no deadline set. Gungin also shares your holdings and trading history with The Gunma Bank.

Access and identity2 clauses flagged

Gungin has made a passkey compulsory for online fund trades and withdrawals. Registering one needs a Our Number card and an NFC phone, or a postal route that resets both of your passwords first.

Why this matters

Choose the postal route and you cannot log in at all until a registered letter reaches you. Gungin sets no deadline for that letter, and it will not be forwarded if you have moved.

Exhibit 9WarningHarder than usual

オンラインサービスでの投資信託取引や出金などの各種取引をご利用いただくためにはパスキーでのログインが必須です。
Clause ① セキュリティ強化について in ご推奨環境・注意事項
Read from the broker's site on Open the reference
  • Worse together with Exhibit 12The service a passkey unlocks is limited to investment trusts, so the identity hurdle buys access to a narrow set of trades.

Gungin shares your name, address, job, holdings and trading history with The Gunma Bank as joint users. It also says it cannot tell you which country your data goes to if it is sent abroad.

Why this matters

The bank that referred you sees what you hold and what you have traded, and uses it to sell you more. You get the destination country only after the transfer has happened, and only if you ask.

Exhibit 10WarningStandard wording

当社は、群馬銀行との連携により、お客さまにより付加価値の高いサービスや金融商品等を提供するため、個人データを共同利用いたします。
Clause 2．個人データの共同利用 in 個人情報保護宣言（プライバシーポリシー）, p.6
Downloaded from the broker's site on Open the reference

Gungin states in four places that it cannot tell you the total

Gungin's fund wrap charges 1.320% a year in advisory fees, with up to 1.50% more taken inside the funds it buys. Four of Gungin's own pages then say the total and the upper limit of those costs cannot be stated. Seeing your own personal data costs ¥1,100, and moving your holdings to another firm reaches ¥11,000.

Cost disclosure1 clause flagged

Ask Gungin for a copy of the personal data it holds on you and it charges ¥1,100, plus postage. Correcting that data or stopping its use is free.

Why this matters

You have to go to a branch counter to ask, with identity documents and the firm's own form. Gungin gives no deadline for its reply, only that it may take time.

Exhibit 11NoticeStandard wording

保有個人データ開示請求 請求書１件につき 1,100 円（消費税込）
Clause 5（2）Ｃ．手数料 in 個人情報保護宣言（プライバシーポリシー）, p.8
Downloaded from the broker's site on Open the reference

Three companies stand behind one Gungin fund wrap

A Gungin securities account is with Gungin Securities, registered Kanto Local Finance Bureau (FIBO) No.2938. A fund wrap contract is with Wealth Square, FIBO No.2914, with Gungin as its agent and Gunma Bank as intermediary. Gungin publishes an outside auditor's report on client asset segregation and names no investor compensation scheme.

Who you contract with2 clauses flagged

Your securities account is with Gungin Securities. Your fund wrap contract is with Wealth Square, a Nomura group company, and Gungin signs it only as Wealth Square's agent.

Why this matters

Neither Gungin nor Gunma Bank manages the money in your fund wrap. The page that sets out its fees was written by Wealth Square, and says it is not a disclosure document under the financial instruments law.

Exhibit 15NoticeStandard wording

お客さまは、代理金融機関(ぐんぎん証券株式会社(以下、「ぐんぎん証券」といいます))を通じて、投資一任業者(株式会社ウエルス・スクエア(以下、「ウエルス・スクエア」といいます))と投資一任契約を締結します。
Clause サービスのしくみ in ファンドラップ
Read from the broker's site on Open the reference

Gungin publishes an outside auditor's report each year confirming it keeps your assets separate from its own. None of its policies names an investor compensation scheme.

Why this matters

Your idle cash sits in MRF, a money fund rather than a deposit, so deposit insurance does not reach it. The segregation report is real evidence, and it is the only protection Gungin points you to.

Exhibit 16NoticeStandard wording

ぐんぎん証券で取扱う商品は預金ではなく、預金保険制度の対象ではありません。また、ぐんぎん証券が、元本を保証するものではありません。
Clause 金融商品仲介業務に関するご留意事項 in 金融商品仲介業務について
Read from the broker's site on Open the reference
Set against a regulated standard: FCA (UK), CySEC (Cyprus)

Firms licensed by the FCA must hold client money in segregated accounts and tell clients that the Financial Services Compensation Scheme covers them up to a stated limit. Gungin publishes an auditor's report on segregation and names no scheme alongside it.

Gungin 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

Gungin says it explains the fund wrap's approximate total cost when it proposes one, while its published page says that total cannot be stated.

Said in public, in Japanese

ファンドラップを提案する際、「重要情報シート」によりお客さまが負担する実質的な費用概算を説明しています。

Word for word in English: When we propose a fund wrap, we explain, using the important information sheet, an estimate of the actual costs the customer will bear.

Page 10 of Gungin's June 2026 progress report on customer-first business operation, under the heading on improving fee transparency

In the contract · clause 投資信託に係る費用

これらの費用の合計額および上限額については、資産配分、運用状況、運用実績等に応じて異なるため、具体的な金額・計算方法を記載することができません。

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of gunginsec.co.jp

02

The deposit and withdrawal page promises same day acceptance until 4pm, while the online service leaflet cuts it off at 3:30pm.

Said in public, in Japanese

お客さまからぐんぎん証券に、午後4時までにご連絡いただいた場合は、原則として翌営業日に登録預金口座にお振込みいたします。

Word for word in English: If you contact Gungin Securities by 4pm, we will as a rule transfer the money to your registered deposit account on the next business day.

Gungin's deposit and withdrawal page, under the heading on withdrawals

We took a picture of this page. It is shown once, with the finding it belongs to. See our capture of gunginsec.co.jp

In the contract · clause ご利用時間 / 出金指示

6：00～15：30（当日受付➡翌営業日振込）

The documents this reading is based on

47 files, all published by Gungin. 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 Gungin publishes.

How this reading was done

Every clause above was read out of a document Gungin publishes itself

This reading was published on .

Documents
11 of 47downloaded from the broker's site, and 11 read in full
Pages opened
44pages walked to find those documents, footer links included
Marketing pages
3public pages set against what the contract says

Who the contract is with

ぐんぎん証券株式会社 (Gungin Securities Co., Ltd.)

A securities account is opened with ぐんぎん証券株式会社, registered as a financial instruments business operator, Kanto Local Finance Bureau (FIBO) No.2938, and a member of the Japan Securities Dealers Association. Gungin is a wholly owned subsidiary of The Gunma Bank. Gunma Bank introduces clients and accepts some orders as a registered financial institution, Kanto Local Finance Bureau (Registered Financial Institution) No.46, but your trades face Gungin and the account sits at Gungin, not at the bank. The fund wrap is the exception: the discretionary management contract is with 株式会社ウエルス・スクエア (Wealth Square, FIBO No.2914, owned by Nomura group companies), with Gungin signing only as its agent and Gunma Bank acting as intermediary. Gungin's own page states that neither Gungin nor Gunma Bank carries out the discretionary management.

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

Deposits are free from any bank, not only from the parent, and Gungin refunds the transfer fee your old broker charged to move assets in. Investment trust purchase fees are 20% cheaper through the online service than across a counter. Gungin does not deal on its own account in Tokyo listed shares: every order goes to the exchange as an agency order, and its best execution policy explains in plain terms why it has not built smart order routing. It publishes an outside auditor's assurance report on client asset segregation every year, which most brokers do not. The fee page lists no account maintenance or dormancy charge. The site and the whole document set are in Japanese, so there is no gap between the language of the marketing and the language of the terms.

The 16 chapters of Gungin's 証券取引約款集, 61 pages of contract terms in all, could not be read. They include the comprehensive trading terms, the custody terms, the online service terms and the discretionary trading terms. Gungin publishes them in a form whose text cannot be copied or searched, so nothing here covers withdrawal refusal, trade cancellation, unilateral amendment or complaint deadlines, which is where those clauses would sit. This review covers 12 policy documents, 4 online service documents and 11 of Gungin's own web pages in full, and every quotation comes from one of those. It covers only part of the 21 page progress report and the correspondence table, and the seminar file no longer loads. No earlier version of these documents is available for comparison.

How to check any of this yourself

Every quote above links to the Gungin 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 Gungin 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 Gungin 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 10, 2026.

If you represent Gungin 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 Gungin. Whether its licence is real and current is a separate check on the broker profile.

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