When you open a position, Rynat can move ownership of your margin from your account to itself. Its own wording then treats that money as a debt the firm owes you, and no longer as your client money.
Why this matters
Client money is protected because it stays yours and sits apart from the firm's own funds. Once ownership moves, you are an ordinary creditor of Rynat for that amount if the firm ever fails.
Exhibit 1Every flagged clause gets its own number so you can point at this one. The number does not change, so a link to it keeps working.CriticalHow much this clause can cost you, in our reading. Critical can take your money or your profit. Warning can delay or limit it. Notice is simply worth knowing before you sign.Rarely seenHow ordinary this wording looks next to the contracts we read. This is our reading of the clause, not a count of other brokers.
It is agree that when opening a position, we have the right to transfer ownership of the amount equivalent to the Margin Requirement from your Account to us, which we will keep as a security in the event of a repayment obligation by you. Any Required Margin transferred shall be considered as our debt due to you and not as Client Money, therefore it will be returned to you on completion of your trade(s), subject to any repayment obligation by you.
Firms supervised by CySEC under the European MiFID II rules must not take ownership of a retail client's money as security for that client's own obligations. Rynat's clause says it may transfer ownership of your margin to itself, and that what it holds is then its debt to you rather than client money.
Rynat is not licensed by these regulators, so this is a comparison of practice, not a finding of any breach.

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