Wikilix
Contract reading

What TD MARKETS legally published, but does not want you to read

Every clause below is published by TD MARKETS 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: TDM Holdings LLC

sole discretionhidden feewithdrawalscomplaint deadlinemarketing gapmissing documentno deadlineprofit voidingundisclosed costunilateral amendment

TD Markets leads with an FSCA licence, but your trades are with TDM Holdings LLC in Saint Vincent and the Grenadines. The homepage promises negative balance protection. The contract grants none, and lets the broker move money between your accounts to cover a negative balance. An inactive account loses 1.5% of its balance every month, and once the balance falls under the $5 minimum fee, the rest is taken.

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.
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.
15
ContradictionsPlaces where a promise the broker makes in public is not kept by the clause that governs it.
6

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.

Critical6
Warning9
Notice1

section 196 of 197is where the deepest clause sits: the very end of 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.

2 of these 3 figures come from a clause we rate critical, which means it can take your money or your profit rather than only delay it.

What the documents say

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

01

You trade with TDM Holdings LLC, a company in Saint Vincent and the Grenadines. The FSCA licence on the marketing belongs to a different company, TD Markets (Pty) Ltd, which the contract casts as the marketing agent and the collector of your money.

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.

Liquidity providers are outside banks and brokers.

Why this matters

Any dispute over your money goes to the courts of Saint Vincent and the Grenadines under clause 34, not to a South African court. The FSCA does not supervise the company holding the other side of your trades.

Exhibit 1CriticalHarder than usual

TDM Holdings LLC (hereinafter the “Principal”), a corporation organized under the laws of Saint Vincent and the Grenadines, acting herein as the principal entity, liquidity provider and counterparty to the trades executed on the Trading Platform as specified in these terms and conditions (hereinafter the “Agreement”).
Quoted in Trading Terms and Conditions, p.1
Read from the broker's site on Open the reference

Buried at section 196 of 197 in the Trading Terms and Conditions, 99% of the way through.

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

Firms licensed by the FCA or CySEC must themselves be authorised to deal as principal before they can be the counterparty to a retail client's CFD trades. Here the FSCA licence covers intermediary services in South Africa, and the counterparty is a separate company in Saint Vincent and the Grenadines.

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

02

TD Markets lists negative balance protection on its homepage and tells you a negative balance will not have to be paid back. The Trading Terms never grant it. Clause 12.4 lets the broker move money out of your other accounts to cover a negative balance.

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

If one account goes below zero, TD Markets can take the shortfall from the balance sitting in your other accounts with them. The promise that brought you in is on a web page, and that page is not the contract you accepted.

Exhibit 2CriticalHarder than usual

Among other rights, that the Principal has in the way of handling these Client Accounts is the transferring of funds between Client Accounts to cover possible negative balances, without this affecting in any way the other rights of the Principal.
Clause 12.4 in Trading Terms and Conditions, p.17
Read from the broker's site on Open the reference

Where it sits: section 102 of 197 in the Trading Terms and Conditions, 52% of the way through.

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

Firms licensed under ESMA rules, and by the FCA and CySEC, must give retail CFD clients negative balance protection on a per account basis. This contract contains no such clause, and clause 4.2 says the entire margin deposit may be lost.

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

  • Worse together with Exhibit 1The protection is promised by the South African entity, and the contract that omits it is with the company in Saint Vincent and the Grenadines.
03

If TD Markets believes your trading affects its platform in any way, clause 27.4 lets it close your account and reverse or cancel every trade you have ever made. The clause sets no test, no evidence standard and no appeal.

Why this matters

Profit you have already made can be unwound months later, on a judgement the broker makes alone. The words affects in any manner cover almost any trading the broker dislikes.

Exhibit 3CriticalHarder than usual

The Principal may terminate this Agreement immediately without giving five (5) business days written notice, and the Principal has the right to reverse and/or cancel all previous Transactions on a Client’s account, in the following cases:
Clause 27.4 in Trading Terms and Conditions, p.26
Read from the broker's site on Open the reference

Buried at section 169 of 197 in the Trading Terms and Conditions, 86% of the way through.

04

Stop trading for 30 days and TD Markets charges you 1.5% of your balance on the 1st of every month, with a $5 minimum and a $50 cap. Once your balance falls below the minimum fee, the terms take whatever is left.

Why this matters

A small account is emptied by this, not just reduced. The clock is 30 days, so one quiet month starts it, and no notice is required before the first deduction.

Exhibit 4CriticalHarder than usual1.5%

A fee of 1.5% of the account balance will be charged on the 1st of each month if the account remains inactive for 30 consecutive days.
Clause 3 in TD Markets Inactivity Fee Terms and Conditions, p.1
Read from the broker's site on Open the reference

What it costsA $1,000 balance loses $15 in the first inactive month. A $200 balance loses the $5 minimum, because 1.5% of $200 is only $3.

What happens, and when

The stages this clause runs through, taken from the broker's own document
TriggerWhat the broker may then doClause
Day 30Your account counts as inactive if you have not traded, deposited or withdrawn.2
1st of each monthTD Markets deducts 1.5% of your balance, at least $5 and at most $50.3
Balance under the minimum feeTD Markets deducts whatever is left and may close the account.4
Day 90An account holding up to 1 cent is archived and the remaining balance is deducted.13.11
Three years with no movementIf TD Markets cannot trace you, it may release any remaining client money from your account.13.10
  • Worse together with Exhibit 9TD Markets sets this fee and separately reserves the right to change any fee without asking you first.
05

You get four business days to object in writing to a trade or a statement. The clock starts on the date of the trade, not the day you spot the problem. Miss it and clause 10.2 makes the statement final and binding on you.

Why this matters

Four business days is one working week. A pricing error you find a fortnight later will not be investigated, because clause 10.3 says TD Markets only looks at objections filed inside that window.

Exhibit 5CriticalHarder than usual4 working days

A statement of account or any certification or any confirmation issued by the Principal in relation to any Transaction or other matter shall be final and binding to the Client, unless the Client files in writing his objection within four (4) business days from the receipt of the said statement of account, certification or confirmation.
Clause 10.2 in Trading Terms and Conditions, p.15
Read from the broker's site on Open the reference

Where it sits: section 93 of 197 in the Trading Terms and Conditions, 47% of the way through.

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

Firms licensed by the FCA and CySEC must run a complaints process for retail clients with a right to escalate to an independent scheme, and they cannot shut off a complaint about a trade after a few days. This contract closes the door four business days after the trade date.

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

  • Worse together with Exhibit 3Your window to challenge a trade closes after four business days, while the broker's right to reverse that same trade has no time limit at all.
06

Deposit money, change your mind and take it back out without placing a trade, and clause 15.8 lets TD Markets charge you 3% of what you deposited. The funding methods document, which is where deposits are explained, never mentions it.

Why this matters

Getting your own untraded money back costs you 3% of it. A reader who studied the funding document before depositing would have seen no fee at all.

Exhibit 6WarningHarder than usual3%

The Client further acknowledges and agrees that in cases where deposits and withdrawals are conducted on the Client account without any trading activity, the Principal reserves the right to charge an administration fee of 3% of the deposited funds to cover any fees/transaction costs incurred by the Principal and the Company on behalf of the Principal as the collection agent.
Clause 15.8 in Trading Terms and Conditions, p.21
Read from the broker's site on Open the reference

Buried at section 132 of 197 in the Trading Terms and Conditions, 67% of the way through.

What it costsA $1,000 deposit taken back out without a single trade costs you $30.

Two safety promises the Trading Terms do not make

TD Markets advertises negative balance protection and client funds held only with top tier banks. Clause 12.4 lets the broker take a negative balance from money in your other accounts. Clause 13.7 permits custody with a third party that does not apply client money rules, and clause 13.9 warns you would have no claim on a specific sum if that party fails.

Page against contract1 clause flagged

TD Markets says it holds client funds only with top tier, investment grade banks. Clause 13.7 lets it hand your money to a payment provider or a third party that does not follow client money rules at all.

Why this matters

Clause 13.9 warns that pooled money cannot be separated from other people's, so you would have no claim on a specific sum if that third party fails. The safety you were shown is narrower in the contract than on the page.

Exhibit 7CriticalHarder than usual

The Client further understands and consents that the Company may hold Client Money on behalf of the Principal with a payment provider or a third party that does not treat such Client Money in accordance with the abovementioned Client Money rules.
Clause 13.7 in Trading Terms and Conditions, p.18
Read from the broker's site on Open the reference

Where it sits: section 110 of 197 in the Trading Terms and Conditions, 56% of the way through.

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

Firms licensed by the FCA and CySEC must hold retail client money with approved credit institutions and keep it identifiable as the client's. This contract lets the money sit with a third party that does not apply those rules.

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

  • Worse together with Exhibit 1An insolvency claim with no identifiable sum would have to be pursued against a company in Saint Vincent and the Grenadines.

A 3% charge for untraded money, in a clause the funding page never mentions

Clause 15.8 lets TD Markets take 3% of a deposit that is withdrawn without any trading. The funding methods document, which is where deposits are explained, sets out no fees at all. Clause 15.9 sends you to a Key Information Document for the cost summary, and TD Markets does not publish one. Clause 15.2 lets the broker change any fee without consulting you.

Cost disclosure2 clauses flagged

Clause 15.2 lets TD Markets change its fees with no consultation and no consent from you. Clause 19.2 has you waive the interest earned on your own money, and the broker keeps it to cover its own expenses.

Why this matters

The price you signed up to is not fixed, and nothing here requires notice before a new rate applies. Interest earned on your balance while it sits with the broker goes to the broker.

Exhibit 9WarningStandard wording

The Client agrees that the Principal is entitled to change its fees unilaterally without any consultation or prior consent from the Client.
Clause 15.2 in Trading Terms and Conditions, p.20
Read from the broker's site on Open the reference

Buried at section 127 of 197 in the Trading Terms and Conditions, 64% of the way through.

For the summary of what trading costs you, clause 15.9 sends you to the Key Information Document. TD Markets does not publish one. Its legal page lists 14 documents and none of them is that.

Why this matters

You cannot check the total cost of trading before you deposit, because the document the contract names does not exist on the site. Clause 15.10 sends you to Trading Conditions, which is also not published as a document.

Exhibit 10WarningHarder than usual

An indicative summary of the cost components and charges derived from the trading of Financial Instruments i.e. CFDs offered by the Principal can be found in the Key Information Document.
Clause 15.9 in Trading Terms and Conditions, p.21
Read from the broker's site on Open the reference

Buried at section 133 of 197 in the Trading Terms and Conditions, 68% of the way through.

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 that client trades. Here the contract defers the cost summary to a document that is not on the broker's legal page.

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

The contract promises no date by which you get paid

TD Markets advertises withdrawals in 24 business hours. Clause 14.6 commits only to a time period specified, and the agreement specifies none. Clause 14.7 lets the broker decline your payment method, demand more documents mid request, and reverse the withdrawal back into your account if it is not satisfied.

Exit conditions1 clause flagged

TD Markets advertises withdrawals in 24 business hours. Clause 14.6 says requests are processed within the time period specified, and the agreement never specifies one. Clause 14.7 also lets the broker refuse your payment method or reverse the withdrawal entirely.

Why this matters

You have no contractual deadline to hold TD Markets to if a payout stalls. If it is not satisfied with a document you send, it can push the money back into your trading account instead of paying you.

Exhibit 8WarningHarder than usual

Fund transfer requests are processed by the Company on behalf of the Principal within the time period specified and the time needed for crediting into the Client’s personal account will depend on the Client’s Bank Account provider.
Clause 14.6 in Trading Terms and Conditions, p.19
Read from the broker's site on Open the reference

Buried at section 121 of 197 in the Trading Terms and Conditions, 61% of the way through.

  • Only applies after Exhibit 13A withdrawal with no deadline becomes open ended the moment the broker asks for one more document.

Withdrawing once removes every bonus on the account

Clause 6 of the TD Markets bonus terms strips all bonus funds the moment any withdrawal is processed. Clause 5 lets the broker remove a bonus at any stage regardless, and clause 7 says bonuses are never withdrawable. The Robo Wars competition terms lock prize credit until a volume figure that the document never states.

Credit removal1 clause flagged

Take any withdrawal and clause 6 of the bonus terms removes all bonus funds from your trading account. Clause 5 lets TD Markets remove a bonus at any stage anyway, and clause 7 says bonuses are never withdrawable.

Why this matters

Touching your own money costs you the credit that was funding your open positions. Losing that credit cuts your margin, which can push positions towards a close out you did not choose.

Exhibit 11WarningStandard wording

In the event a withdrawal is processed on a trading account or landing account, all bonus funds shall be removed from the trading account.
Clause 6 in Smart Account Bonus Terms and Conditions, p.1
Read from the broker's site on Open the reference

Leverage, spreads and the agreement itself can change without you

TD Markets advertises leverage up to 1:2000 on all forex pairs, and clause 6.22 caps it at 1:100 every Friday between 21:00 and 24:00 and around major news. The same clause lets the broker change your leverage at any time without consent. Clause 6.17 allows discretionary spread widening, and clause 29.7 permits amendment on notice given in writing or otherwise.

Terms in motion1 clause flagged

TD Markets advertises leverage up to 1:2000 on all forex pairs. Clause 6.22 caps it at 1:100 every Friday evening and around major news, and lets the broker change your leverage at any time without your consent.

Why this matters

A leverage cut shrinks the position you can hold and can force you to add margin at the worst moment. Clause 6.17 also lets TD Markets widen spreads at its discretion, which raises your cost to trade.

Exhibit 12WarningStandard wording

The Client acknowledges that on every Friday and between the hours of 21:00 until 24:00 and occasionally before the release of major economic news, the Principal maintains a maximum leverage of 1:100 on FX and 4 times the standard Margin requirement on remaining instruments other than FX, namely commodities, indices, futures and equities for any new positions opened during the said specified period.
Clause 6.22 in Trading Terms and Conditions, p.12
Read from the broker's site on Open the reference

Where it sits: section 72 of 197 in the Trading Terms and Conditions, 37% of the way through.

You have four business days to challenge a trade

Clause 10.3 gives you four business days from the date of a trade to object in writing, and clause 10.2 makes an unchallenged statement final and binding. The clock runs from the trade, not from the day you notice. On social trading, clause 5 of the Social Trading Agreement makes you jointly and severally liable to cover TD Markets for the lead trader's actions.

In plain words

Jointly and severally liable means each person can be made to pay the whole amount alone. If the broker treats two accounts as linked, it can ask either holder for all of it, not half each.

Complaint window1 clause flagged

Follow someone on social trading and clause 5 makes you and the lead trader jointly and severally liable to cover TD Markets for losses and legal fees. Joint and several means the broker can pursue you alone for the whole amount.

In plain words

Indemnities are money it says you owe it.

Why this matters

A decision the lead trader made, which you never saw, can become a bill addressed to you. Clause 6 lets TD Markets take those costs straight out of your account on demand.

Exhibit 15WarningRarely seen

The Trader and Master Account holder each, jointly and severally hereby agrees to indemnify and hold TDM, its employees, agents, affiliates, successors, assigns and affiliates harmless from and against all liabilities, losses, damages, cost and expenses, including attorney's fees that arise directly or indirectly from the replication of trades executed on the Master Account on the Trader’s account
Clause 5 in Social Trading Agreement, p.1
Read from the broker's site on Open the reference

Where it sits: section 7 of 20 in the Social Trading Agreement, 35% of the way through.

Our readingJoint and several indemnity is a commercial lending device. Pointed at a copy trading follower, it means a stranger's conduct can be charged to your balance in full.

TD Markets can stop acting on your orders until you satisfy it

Clause 24.3 lets TD Markets refuse to carry out your orders for as long as requested information is outstanding, with no deadline on either side and no responsibility for the delay. Clause 26.2 lets it pass your personal information to third parties without informing you, where it decides you are directly or indirectly involved in fraud.

Document holds1 clause flagged

Clause 24.3 lets TD Markets refuse to carry out your orders for as long as you have not supplied information it has asked for. No deadline binds the broker, and it accepts no responsibility for the delay.

Why this matters

Open positions can sit frozen while a document request is unresolved. Clause 26.2 also lets TD Markets pass your personal information to third parties without telling you, if it decides you are indirectly involved in fraud.

Exhibit 13WarningStandard wording

The Principal has the right not to carry out orders or instructions received from the Client, and the Principal has the right not to execute orders or carry out instructions received, as long as the Client has not supplied information requested by the Principal.
Clause 24.3 in Trading Terms and Conditions, p.25
Read from the broker's site on Open the reference

Buried at section 158 of 197 in the Trading Terms and Conditions, 80% of the way through.

Your orders go to one venue, and it is the broker itself

The Order Execution Policy names TDM Holdings LLC as the sole execution venue for all client orders and as the counterparty to each one. It tells you plainly that you carry the risk of that counterparty defaulting. The Conflict of Interest Management Policy addresses only the South African intermediary and never mentions this arrangement.

Both sides of the trade1 clause flagged

TDM Holdings LLC is the only place your orders go, and it sets the prices you trade on. Its own Order Execution Policy warns you carry the risk of that counterparty defaulting.

Why this matters

When you lose, the company on the other side of the trade gains. The Conflict of Interest Management Policy covers only the South African intermediary and never mentions this arrangement.

Exhibit 14WarningStandard wording

The Principal will enter into all transactions with the client as principal (counterparty) and act as the sole Execution Venue for all client orders.
Clause 10 in Order Execution Policy, p.11
Downloaded from the broker's site on Open the reference

Where it sits: section 24 of 43 in the Order Execution Policy, 56% of the way through.

Fourteen documents, and none of them is a risk disclosure

TD Markets publishes no standalone risk disclosure, no anti money laundering policy and no client categorisation policy. The risk warning sits inside the 31 page Trading Terms, where clause 4.11 says there may be risks beyond those listed. The complaints route that does exist runs through the South African company and caps a FAIS Ombud claim at R800,000.

Document set1 clause flagged

TD Markets publishes 14 legal documents. None is a risk disclosure, an anti money laundering policy or a client categorisation policy. The risk warning lives inside the Trading Terms, and clause 4.11 says the list of risks there is incomplete.

Why this matters

You have to read a 31 page contract to find the risk warning, and it tells you there are other risks it does not name. The complaints route that does exist runs through the South African company and is capped at R800,000.

Exhibit 16NoticeHarder than usual

The Client acknowledges and accepts that there may be risks other than those mentioned in this clause 4.
Clause 4.11 in Trading Terms and Conditions, p.6
Read from the broker's site on Open the reference

Where the marketing and the contract disagree

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

01

The FSCA licence is held by the South African marketing company, while the company you actually trade with sits in Saint Vincent and the Grenadines and does no business in South Africa.

Said in public, in English

TD Markets (Pty) Ltd is an Authorised Financial Services Provider with the Financial Sector Conduct Authority FSP49128.

Licenses and Regulators page, English

In the contract · clause 1

The Principal does not provide any products or services in South Africa.

02

The page says a negative balance is never paid back, and clause 12.4 lets the broker cover it from money in your other accounts.

Said in public, in English

even if the markets move extremely rapidly a negative balance by a customer will not be due to be paid back by the customer.

Security of funds page, English

In the contract · clause 12.4

Among other rights, that the Principal has in the way of handling these Client Accounts is the transferring of funds between Client Accounts to cover possible negative balances, without this affecting in any way the other rights of the Principal.

03

The word only on the marketing page is contradicted by a clause permitting custody with a payment provider that does not apply client money rules.

Said in public, in English

TD Markets holds client funds only with top tier, investment grade banks.

Security of funds page, English

In the contract · clause 13.7

The Client further understands and consents that the Company may hold Client Money on behalf of the Principal with a payment provider or a third party that does not treat such Client Money in accordance with the abovementioned Client Money rules.

04

A 24 business hour payout is promised in marketing, while the contract commits only to a time period it never specifies.

Said in public, in English

Client withdrawals are processed in 24 hours (business hours) showing TD Markets commitments to ensure our clients have assurance of access to their funds.

Security of funds page, English

In the contract · clause 14.6

Fund transfer requests are processed by the Company on behalf of the Principal within the time period specified and the time needed for crediting into the Client’s personal account will depend on the Client’s Bank Account provider.

05

Leverage advertised as available on all forex pairs is cut to 1:100 every Friday evening and around major news.

Said in public, in English

Up to 1:2000 leverage available on all Forex pairs

Homepage, Trade With A TDM MAX Account section, English

In the contract · clause 6.22

The Client acknowledges that on every Friday and between the hours of 21:00 until 24:00 and occasionally before the release of major economic news, the Principal maintains a maximum leverage of 1:100 on FX and 4 times the standard Margin requirement on remaining instruments other than FX, namely commodities, indices, futures and equities for any new positions opened during the said specified period.

06

The contract sets dormancy at one year and $50, while a separate document on the same legal page sets it at 30 days and 1.5% of the balance every month.

Said in public, in English

The Client acknowledges and accepts that in the case of no activity, including funding or trading, within one year, the Principal reserves the right to charge an annual fixed administrative fee of 50 USD (or currency equivalent), subject to the Client having sufficient funds available.

Trading Terms and Conditions clause 15.11, the contract accepted at signup

In the contract · clause 3

A fee of 1.5% of the account balance will be charged on the 1st of each month if the account remains inactive for 30 consecutive days.

The documents this reading is based on

15 files, all published by TD MARKETS. 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 TD MARKETS publishes.

How this reading was done

Every clause above was read out of a document TD MARKETS publishes itself

This reading was published on .

Documents
11 of 15downloaded from the broker's site, and 11 read in full
Pages opened
24pages walked to find those documents, footer links included
Older copies
5earlier versions downloaded, 6 identical to the copy we hold by fingerprint
Marketing pages
11public pages set against what the contract says
Position measured
13clauses whose position was counted: which numbered section of the document holds them, out of how many

Who the contract is with

TDM Holdings LLC

Two companies sit behind this brand. TD Markets (Pty) Ltd is registered in South Africa and holds FSCA licence 49128. Its own Trading Terms cast it as the marketing agent and the collector of your money, not as your trading counterparty. TDM Holdings LLC, registered in Saint Vincent and the Grenadines, is the company you actually trade with. The Trading Terms call it the Principal, the liquidity provider and the counterparty to every trade. The Order Execution Policy states that this Saint Vincent company does not provide any products or services in South Africa.

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

TD Markets publishes all 14 of its legal documents on one page, as free PDFs, with no login. The Complaints Resolution Policy names a real person, a street address and an email, and sets a six week target with escalation to the FAIS Ombud. Most offshore brokers name nobody. The Order Execution Policy admits plainly that the broker is the sole execution venue and that you carry counterparty default risk. Clause 13.3 says title transfer collateral arrangements are not used with retail clients, so ownership of your money stays with you. Clause 7.2 fixes a 50% margin close out for retail clients instead of leaving it open. The inactivity fee is capped at $50 a month.

We did not open the Cookie Policy at all. We read only parts of the Privacy Policy and the Complaints Resolution Policy, enough to check retention, data sharing and complaint deadlines, and not end to end. The copy of the Order Execution Policy served to us stopped partway, so we quote only from the part we read in full. TD Markets blocks automated access to its marketing pages, and every claim we quote is from a TD Markets page we opened. Three archived earlier copies would not download, the IB Competition terms, the TDM Boost bonus terms and an older Order Execution Policy, so we could not compare those against today's versions. We also found a document our set was missing: the legal page links a file called 20% Bonus Terms and Conditions, and its text matches the Smart Account bonus terms word for word, with no mention of 20%.

How to check any of this yourself

Every quote above links to the TD MARKETS 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 TD MARKETS 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 TD MARKETS 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 22, 2026.

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