November 1, 2019 Dispositions against members of the Financial Futures Association of Japan Today, the Association took the following actions against members of the Association based on Article 19, Paragraph 1 of the Articles of Incorporation. Note 1. Name of the association member who received the disposition FX Broadnet Co., Ltd. 2. Disciplinary action Remarks 3. Reason for Disposition ① At the company, regarding the examination of spread advertisements, the person in charge of the system department verifies monthly based on the results of the previous month and obtains approval from the Director of the Compliance Department and the General Manager of the Foreign Exchange Division. If there is a difference between the display and the actual value (when the actual value described in the Association's "Q&A Case Examples Concerning Display of Advertisements and Offering of Premiums" falls below 95% of the advertisement display rate), A meeting of the emergency task force attended by the president, the general manager of the compliance department, and the general manager of the foreign exchange headquarters will be held to discuss the response. (ii) In the on-site audit conducted by the Audit Department of the Association, when the details of verification of spread advertisements were confirmed, it was found that there were currency pairs whose actual spread presentation rate from November 2018 to February 2019 was below 95%. was taken. Of these, in December 2018 and January 2019, results were significantly lower than the ad presentation rate for multiple currency pairs, including major currency pairs such as the US dollar and the euro yen, especially for the euro yen and pound yen. was confirmed to have fallen for three consecutive months. (3) In response to the above situation, the Emergency Response Headquarters meeting held said, "We will consider reviewing the display of advertisements in the event that we are unable to meet the rate of display of advertisements in the future." However, no specific measures were taken, such as correcting the spread displayed in the advertisement or canceling the advertisement. 4) Based on the above, since the Association's rule "Self-regulatory rules on the display of advertisements and the provision of premiums" was revised in June 2014 to stipulate spread advertisements, the advertisement display rate has continued to fall significantly below the rate. In addition, the company has held an emergency task force meeting to be held when the advertisement display rate is below Considering the fact that no appropriate measures have been taken, it is recognized that the company's internal control system was inadequate. 4. In addition to this disposition, on the same date, based on Article 16 of the Articles of Incorporation, we made a recommendation to thoroughly comply with laws and regulations and to enhance and strengthen the internal control system. that's all