Wow! I'm an ECN/STP broker which passes trades on to external LPs - except the biggest LP is under the same ownership and sits inside the same office.
I have to say I find this to be bitterly disappointing. Too bad the CFTC didn't send Drew and William off to spend a couple years in Club Fed, followed by a public caning.
While I cannot speak about the NFA or CFTC complaint specifically due to the nature of our settlement, I can say that we have settled with the NFA and CFTC without admitting or denying any of their allegations or claims. Effex Capital is no longer pricing FXCM's NDD forex price feed. Note FXCM would not have suffered more than $200 millon dollars in losses during the SNB flash crash had it been taking the other side of client trades – unlike so many of the DD firms in the industry.
I can also discuss with you FXCM's execution practices outside of the US. FXCM uses 16 liquidity providers to create a best bid best offer price stream for clients. LPs selected to price retail clients are forced to adhere to an extremely high standard of execution beyond just price – including consistently low rejection rates, low latency, minimum quote sizes and high fill ratios even during market events.
We have made our execution study public in the UK which can be viewed here and is a transparent comparison of FXCM's actual execution vs top tier futures brokers and the interbank market.