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Contract reading

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

Every clause below is published by Masumo 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: 益茂証券株式会社 (Masumo Securities, Inc.)

hidden feecost disclosureconflict of interestpromotion termssole discretionbest executionbonus lockcommission floorcomplaintscurrency conversion

Masumo is a 150 year old registered Japanese broker, and the story here is cost, not confiscation. A stock trade costs up to 1.265% and never less than ¥2,750. Foreign trades add ¥0.50 per US dollar in currency markup, which the fee notice never mentions. Masumo's own best execution policy says comparing trading venues could get you a better price, then records its decision not to do it.

Contract risk

Harder than average
4.6/10

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.
13
DocumentsHow many of the broker's own legal files this reading is based on. Each one was downloaded and hashed on the date shown.
20
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
2

How the 13 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
Warning8
Notice5

section 78 of 84is where the deepest clause sits, 93% of the way into the document it is in

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.

What the documents say

13 clauses worth knowing about, worst first, each quoted from Masumo's own files

01

You pay up to 1.265% of the trade value in commission on a Japanese stock trade, and never less than ¥2,750. Masumo sets that floor in a commission schedule that sits on its fee page, not with the twelve policies in the footer.

Why this matters

A ¥100,000 trade costs you ¥2,750, which is 2.75% of the money you put in. Buy and sell once and commission alone takes ¥5,500 out of that ¥100,000.

Exhibit 1WarningStandard wording1.27%

株式の売買取引には、約定代金に対し最大1.265%(税込み)(手数料金額が2,750円を下回った場合は2,750円(税込み))の手数料をいただきます。
Quoted in 手数料およびリスクについての重要な注意事項, p.1
Read from the broker's site on Open the reference

What it costsA ¥500,000 stock trade costs ¥6,325 in commission, the figure Masumo prints in its own worked example. A ¥100,000 trade costs ¥2,750, because the floor replaces the rate.

  • Worse together with Exhibit 5The floor makes a small trade expensive, and moving the shares to a cheaper broker costs ¥6,600 for each holding.
  • Worse together with Exhibit 9Masumo publishes these figures on the same website whose terms say the figures are not guaranteed and can change without notice.
02

Masumo adds ¥0.50 per US dollar when it turns a foreign share trade into yen, using a mid rate it sets itself. The fee notice on its policy shelf never mentions this charge.

Why this matters

On a $10,000 trade the conversion alone costs you ¥5,000, before the 1.375% commission and the foreign market's own charges. Sell the shares later and you pay the markup a second time.

Exhibit 2WarningHarder than usual$0.5

◇円貨決済での売買の場合、受渡代金を計算する際に用いる為替レートは国内約定日に当社が定める仲値に以下の金額を加減した為替レートとなります。
Clause (外国株式:国内取次手数料) in 売買委託手数料表, p.3
Read from the broker's site on Open the reference

What it costsA $10,000 foreign share purchase settled in yen carries ¥5,000 of currency markup at ¥0.50 per dollar. Buying and selling once costs ¥10,000.

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

Firms licensed by the FCA, and firms under ESMA rules, must show a retail client the total cost of a trade before it is placed, including any currency conversion charge. Masumo's fee notice names the commission and the foreign market's charges. The ¥0.50 per dollar amount appears only in the separate commission schedule.

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

  • Worse together with Exhibit 1A foreign share trade pays the commission and the currency markup together, and only the commission is in the fee notice.
03

Masumo writes in its own best execution policy that comparing the best quotes across several venues could be the best execution for you. It then says it will not do that, because it would have to build the systems first.

Why this matters

Your order goes to one exchange picked in advance, so a better price elsewhere at that moment never reaches you. Masumo adds that a price which later proves not to have been the best is not by itself a failure of its duty.

Exhibit 6WarningHarder than usual

PTSを含め複数の金融商品市場等から最良気配を比較し、より価格を重視することはお客様にとって最良の執行となり得ると考えられます。
Clause 2.(1)②(イ) in 最良執行方針, p.2
Read from the broker's site on Open the reference
Our own capture of masumo.co.jp, taken on Aug 31, 2026The claim, on Greeting and management philosophy page, signed by the presidentVisit this page on the broker's siteDownload the full size image file

Where it sits: section 10 of 22 in the 最良執行方針, 45% of the way through.

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

Firms licensed by the FCA, and firms under ESMA rules, must take all sufficient steps to obtain the best possible result for a retail order, and the choice of venue is part of that test. Masumo's policy states that comparing venues could be the best execution for a customer, and that it has decided against doing so at this stage.

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

  • Worse together with Exhibit 7Masumo will not look for a better venue, and it will not accept your instruction to close a margin position on a different one.
04

You pay no commission on a bond bought from Masumo, and its fee notice says the purchase price is all you pay. Masumo sets that price itself, and says the price you buy at is generally higher than the price you sell at.

Why this matters

The gap between those two prices is what Masumo earns on the trade, and no document puts a number on it. You cannot weigh the cost against another firm, because there is no figure to compare.

Exhibit 4WarningStandard wording

債券を募集・売出し等により、または当社との相対取引により購入いただく場合は、購入対価のみをお支払いいただきます。
Quoted in 手数料およびリスクについての重要な注意事項, p.2
Read from the broker's site on Open the reference
Our own capture of masumo.co.jp, taken on Aug 31, 2026What the contract says, clause ※店頭取引でのご購入・ご売却についてVisit this page on the broker's siteDownload the full size image file
Set against a regulated standard: FCA (UK), ESMA (EU)

Firms licensed by the FCA, and firms under ESMA rules, must tell a retail client the cash cost of a bond trade before dealing, including a markup built into the price rather than charged as commission. Masumo's fee notice says the purchase price is all that is payable, and names the price difference without quantifying it.

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

05

Keeping your shares at Masumo is free, but taking them to another broker costs you up to ¥6,600 for each stock. Funds, bonds and foreign shares cost ¥3,300 each to move out.

Why this matters

Five holdings transferred out cost you ¥33,000, whatever they are worth. The charge lands when you leave, which is the moment a customer least expects a bill.

Exhibit 5WarningStandard wording$6600

また、証券保管振替機構を通じて他社への株式を口座振替する場合は、口座振替する数量に応じて、1銘柄あたり6,600円(税込み)を上限として口座振替手続料をいただきます。
Clause <口座管理料について> in 手数料およびリスクについての重要な注意事項, p.1
Read from the broker's site on Open the reference

What it costsFive Japanese stocks moved to another broker cost ¥33,000 at ¥6,600 each. Five funds cost ¥16,500 at ¥3,300 each.

The fee page names the commission and leaves out the currency markup

A Japanese stock trade at Masumo costs up to 1.265% of the trade value and never less than ¥2,750. Foreign trades add ¥0.50 of currency markup for every US dollar, at a mid rate Masumo sets, and the fee notice on its policy shelf does not mention that charge. Bonds carry no commission at all, and instead a margin inside the price that no document puts a number on.

Cost disclosure1 clause flagged

You pay up to 3.85% of your money as a subscription fee when you buy an investment trust through Masumo. A trust fee of up to 2.09% a year comes out of the fund on top, and cashing out can cost another 0.5%.

Why this matters

Put in ¥1,000,000 and ¥38,500 goes on the subscription fee before the fund buys anything for you. Masumo also says it cannot state your total cost, because that depends on how long you hold.

Exhibit 3WarningStandard wording3.85%

投資信託のお申込みにあたっては、お申込み金額に対して最大3.85%(税込み)の申込手数料をいただきます。
Quoted in 手数料およびリスクについての重要な注意事項, p.2
Read from the broker's site on Open the reference

What it costsA ¥1,000,000 fund purchase pays ¥38,500 in subscription fee at 3.85%. The 2.09% trust fee takes a further ¥20,900 in the first year.

You accept the site terms by arriving, read or unread

Masumo's website terms treat any use of the site as acceptance, whether or not you read them, and exclude all liability for a loss based on the site's contents. The site is where the fee tables live. The fee notice adds that its figures and tables are not guaranteed and can change without notice.

Terms and liability1 clause flagged

Masumo's website terms say that by using the site you have accepted them, whether or not you actually read them. The same terms rule out any liability for a loss you suffer based on what the site says.

Why this matters

The site is where Masumo publishes its fee tables. Its fee notice adds that the wording, the figures and the tables are not guaranteed to be accurate or complete, and can change without telling you first.

Exhibit 9WarningHarder than usual

本サイトをご利用になる場合、本諸条項を実際に読んだか否かにかかわらず、本諸条項に承諾いただいたものとみなされます。
Clause 本サイトのご利用にあたり in ますも証券のWebサイトのご利用にあたり, p.1
Downloaded from the broker's site on Open the reference

Masumo names the better way to fill your order and declines to build it

Masumo's best execution policy says comparing prices across venues could give a customer the best result, then records its decision not to do it because of the systems it would have to build. Its conflict of interest policy covers one company, itself, while Okasan Securities lends it the money for margin loans and a parent broker holds the shares.

Execution and conflicts1 clause flagged

Masumo's conflict of interest policy lists the companies it covers, and the list has one name on it: Masumo itself. Its own disclosure shows it borrows the money for its margin lending from Okasan Securities, and holds customer securities through a parent broker.

Why this matters

The group that funds Masumo's lending to you, and that holds your shares, sits outside the policy written to manage conflicts. Masumo's accounts show ¥12,360 thousand of dealings with related companies in the year, and one related company owns 24.41% of it.

Exhibit 8WarningHarder than usual

利益相反管理の対象となる会社は、以下のとおりです。
Clause 5 in 利益相反管理方針の概要, p.1
Read from the broker's site on Open the reference

Buried at section 78 of 84 in the 利益相反管理方針の概要, 93% of the way through.

The NISA cash offer changed quietly and reads two ways

Masumo's ¥1,000 NISA cash payment now excludes anyone who has received it before, a bar that was not in the February 2026 copy of the same flyer. That flyer also carries two campaign periods and two qualifying amounts, one from 2023 and one from 2026. Masumo can change or end the offer for its own convenience.

Promotion terms2 clauses flagged

Masumo changed who qualifies for its ¥1,000 NISA cash payment since the February 2026 copy of the same flyer. A customer who has ever taken this payment before is now shut out.

Why this matters

If you took the ¥1,000 once, you cannot take it again. Masumo can also change, suspend or end the offer for its own convenience, and it pays the cash around the middle of the month after the one you qualified in.

Exhibit 11NoticeStandard wording$1000New

・1回限りのため以前に当社で「ますも証券NISAお客様キャンペーン≪つみたて投資枠≫」にて現金進呈を受けたことがあるお客様は対象外とさせていただきます。
Clause (注2)【対象外となるお客様】 in ますも証券NISA お客様キャンペーン, p.2
Read from the broker's site on Archived copyOpen the reference

The NISA campaign flyer on Masumo's site carries two different campaign periods and two different qualifying amounts. The top asks for ¥500,000 of buying in a 2023 window. The main box offers ¥5,000 for using ¥1,000,000 of growth quota in 2026.

Why this matters

You cannot tell from the flyer which set of terms applies to you, or how much you have to buy to qualify. Masumo can point to either set.

Exhibit 12NoticeHarder than usual

【キャンペーン期間】令和5年1月4日(水)~12月29日(金)
Clause 【キャンペーン期間】 in ますも証券NISA お客様キャンペーン, p.1
Read from the broker's site on Archived copyOpen the reference

A margin position closes where it opened, whatever you ask for

Masumo closes a margin position on the same exchange where it was opened, and says it cannot accept an instruction to use another one. For standard margin trading the market's rules require it. For negotiable margin trading Masumo applies the same rule and gives no reason.

Order handling1 clause flagged

If you open a margin position with Masumo, it closes that position on the same exchange, and says it cannot accept your instruction to use a different one. For standard margin trading the policy gives the market's own rules as the reason.

Why this matters

You lose the choice of where your closing trade goes, even when you ask for another market. Masumo applies the same rule to negotiable margin trading, where it gives no reason.

Exhibit 7NoticeStandard wording

また、お客さまからご指示があっても、新規建てと同一市場以外での反対売買の執行はお受けできません。
Clause 2.(1)②(イ)(b) in 最良執行方針, p.2
Read from the broker's site on Open the reference

Buried at section 16 of 22 in the 最良執行方針, 73% of the way through.

Asking Masumo what it knows about you costs ¥1,100

Masumo charges ¥1,100 for each request to see the personal data it holds about you. It also gathers information on you from third party databases, from newspapers and public records, and by recording calls. The same data can be used to sell you a partner company's products.

Data access1 clause flagged

You pay ¥1,100 for each request to see the personal data Masumo holds about you. Masumo also gathers data on you from third party databases, from the press and public records, and by recording calls.

Why this matters

Checking what a firm holds on you costs money, and the fee applies to every request. Masumo can also use the same data to sell you the products of the companies it partners with.

Exhibit 10NoticeStandard wording$1100

なお、保有個人データの開示に関するご請求につきましては、1件につき1,100円(消費税込み)を請求させていただきます。
Clause 8 in 個人情報保護宣言・個人情報保護方針
Read from the broker's site on Open the reference

Buried at section 20 of 23 in the 個人情報保護宣言・個人情報保護方針, 87% of the way through.

A registered Fukui broker with audited segregation and a complaints route

Masumo has been registered with Japan's Hokuriku Local Finance Bureau since 30 September 2007, registration number 12. It belongs to the Japan Securities Dealers Association and the Japan Investor Protection Fund, and an outside accountant audits how it keeps client assets separate. Complaints can go to FINMAC, which it joined in April 2011.

Registration1 clause flagged

Masumo has been registered as a financial instruments business operator with Japan's Hokuriku Local Finance Bureau, number 12, since 30 September 2007. It belongs to the Japan Securities Dealers Association and to the Japan Investor Protection Fund.

Why this matters

You have a route to an independent complaints body, FINMAC, which Masumo signed up to in April 2011. An outside accountant checks that Masumo keeps your assets separate from its own.

Exhibit 13NoticeStandard wording

益茂証券株式会社 金融商品取引業者 北陸財務局長(金商)第12号 加入協会/日本証券業協会
Quoted in 当社の勧誘方針, p.1
Read from the broker's site on Open the reference

Where it sits: section 25 of 84 in the 当社の勧誘方針, 30% of the way through.

Where the marketing and the contract disagree

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

01

The president's page puts the customer first, while the best execution policy sets the firm's own systems cost above a better price for that customer.

Said in public, in Japanese

お客様第一主義を経営の信条とし、安全・安心の資産運用サービスのご提供を行います。

Word for word in English: We make customer first our management creed, and provide safe and secure asset management services.

Greeting and management philosophy page, signed by the president

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

In the contract · clause 2.(1)②(イ)

当社でこのような執行を行うためにはシステム開発等を行う必要がありますが、これによってお客様が得られるであろう効果および影響を当社内で検討した結果、現段階ではPTSへの取次ぎを含む取引所外売買の取扱いをせず、国内の金融商品取引所市場に取り次ぐことが最も合理的であると判断いたします。

02

The fee notice says a bond costs you the purchase price and nothing more, while the risk page admits the price itself is set with a margin in Masumo's favour.

Said in public, in Japanese

債券を募集・売出し等により、または当社との相対取引により購入いただく場合は、購入対価のみをお支払いいただきます。

Word for word in English: Where you buy a bond through an offering or sale, or in an over the counter trade with us, you pay only the purchase consideration.

Fee and risk notice on the footer policy shelf, bond section

In the contract · clause ※店頭取引でのご購入・ご売却について

なお、ある時点で同じ債券に対して当社から提示する価格は、お客様の購入価格が売却価格よりも高く設定されることが一般的です。この価格差を「スプレッド」ということがあります。

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

What changed quietly

This is our first reading of Masumo, so there is nothing yet to compare it with.

  • ADDEDClause (注2)【対象外となるお客様】 · 2026-02-20 to 2026-08-31

    A customer who has taken the ¥1,000 payment once can never take it again.

    ・1回限りのため以前に当社で「ますも証券NISAお客様キャンペーン≪つみたて投資枠≫」にて現金進呈を受けたことがあるお客様は対象外とさせていただきます。
  • REMOVEDClause · 2026-02-20 to 2026-08-31

    The condition that your first contribution had to fall inside the campaign period is gone.

The documents this reading is based on

20 files, all published by Masumo. 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 Masumo publishes.

How this reading was done

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

This reading was published on .

Documents
15 of 20downloaded from the broker's site, and 15 read in full
Pages opened
23pages walked to find those documents, footer links included
Older copies
9earlier versions downloaded, 4 identical to the copy we hold by fingerprint
Marketing pages
3public pages set against what the contract says
Position measured
5clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

益茂証券株式会社 (Masumo Securities, Inc.)

You contract with 益茂証券株式会社, a Fukui company registered with Japan's Hokuriku Local Finance Bureau as financial instruments business operator number 12. There is no second entity and no offshore arm: one company runs all four branches. Two related parties matter. 益茂ビル株式会社 owns 24.41% of Masumo and appears in Masumo's own disclosure as a related company. The Okasan group holds about 14% of the shares, lends Masumo the money it uses for margin loans, and is the broker through which your securities are held.

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

Masumo charges nothing to hold your shares: its fee notice says the account management fee is free. An outside accountant audits how it keeps client assets separate from its own, it belongs to the Japan Investor Protection Fund, and it publishes a complaints desk with a phone number and opening hours next to the independent FINMAC route it joined in April 2011. Japanese law governs, and the courts are where its customers live. It also leaves old versions of its pre-contract documents online, dated back to 2013 in places, instead of replacing them quietly. Nothing we read lets Masumo void a profit, refuse a withdrawal, or charge a fee for leaving an account idle.

We could not read three documents. The customer first business operation policy contains no text at all, only two page images, so it cannot be searched or copied, and we quoted nothing from it. We also could not read the custody contract explanation or the listed securities document, which are the two documents closest to an account contract. Those two, and the commission schedule, are not on the footer policy shelf: we found them on the fee and risk page instead. The website terms of use would not open as readable text, so we read them from the document as it displays, and both quotations credited to it come from there. We did not read the four earlier copies that match today's files by fingerprint, and three earlier copies could not be downloaded. We also did not check the separate pre-contract documents for government bonds, yen bonds and foreign currency bonds.

How to check any of this yourself

Every quote above links to the Masumo 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 Masumo 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 Masumo 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 Aug 31, 2026.

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