1. Introduction to Fundamental Analysis

Fundamental analysis in Forex trading is the comprehensive study and evaluation of the underlying economic, financial, political, and social factors that influence the relative value of a nation's currency. Unlike technical analysis, which focuses on historical price patterns and chart formations, fundamental analysis seeks to determine the intrinsic "value" or "strength" of a currency by examining the health and prospects of its issuing economy. The core premise is that a nation with a strong, growing, and stable economy, prudent monetary and fiscal policy, and positive capital inflows will see demand for its currency increase, causing its value to appreciate relative to currencies from weaker economies.

Why does this matter in the Forex market, the largest and most liquid financial market in the world? Forex is the conduit for global capital. Every international trade, cross-border investment, multinational corporate transaction, and sovereign wealth fund allocation requires currency exchange. The flows of this capital are dictated by fundamental drivers. While technical factors dominate very short-term price action, the medium to long-term trends in currency pairs are overwhelmingly driven by fundamental narratives—primarily divergences in interest rate expectations and economic growth trajectories between countries. A trader who understands fundamentals understands why the market is moving, not just that it is moving. This provides context, helps in anticipating major trend changes, and allows for high-conviction positioning around macroeconomic events.

Fundamental analysis differs from technical analysis in its data sources, time horizon, and philosophical approach. Technical analysis is introspective, looking only at the price action of the market itself, treating it as the ultimate distillation of all known information. It operates on the belief that price discounts everything. Fundamental analysis is extrospective, looking outward at the real-world conditions that cause market participants to buy or sell. It operates on the belief that price will eventually converge with economic reality. Technicians study charts; fundamentalists study central bank statements, GDP reports, and election polls. In practice, these approaches are not mutually exclusive but complementary. A fundamentalist might identify a long-term bias (e.g., bullish on USD due to Fed tightening), while a technician identifies the optimal entry point within the prevailing trend.

The role of fundamental analysis in macro trading is paramount. Macro traders—including hedge funds, asset managers, and proprietary trading desks—construct trades based on top-down global economic themes. These are not mere bets on a single data point but sophisticated narratives. Examples include "the great monetary policy divergence" (trading the widening interest rate gap between the US and Eurozone), "the commodity super-cycle" (going long currencies of resource-exporting nations like AUD and CAD), or "safe-haven flows" (buying JPY or CHF during geopolitical crises). These trades can last for months or even years and involve complex combinations of currency pairs, bonds, and derivatives. For the retail trader, engaging in fundamental analysis means elevating their perspective from chasing pips to understanding the global economic currents that move billions of dollars daily. It transforms trading from a game of reactions into a discipline of strategic anticipation.

2. What Moves Currency Prices Fundamentally

At its most basic, a currency's price, like any asset, is determined by supply and demand. However, in the Forex market, these forces are not driven by corporate earnings or product cycles but by vast, complex macro flows. The fundamental drivers can be categorized into several interconnected layers.

Interest Rate Differentials and Expectations. Currencies are essentially debt instruments of their central banks. Investors globally seek the highest risk-adjusted return on their capital. If the US Federal Reserve is raising interest rates while the European Central Bank holds steady, dollar-denominated assets (like US Treasury bonds) become more attractive. To buy these assets, international investors must first buy US dollars, increasing demand for USD and causing EUR/USD to fall. Crucially, the market trades on expectations of future rates more than on current rates. This is why a central bank signaling a pause after a hiking cycle can cause its currency to weaken, even if the current rate is high.

Economic Growth and Performance. A strong, growing economy attracts foreign investment in equities, real estate, and direct business investment. This requires converting foreign currency into the local currency, creating demand. Strong growth also suggests a central bank may need to raise rates to prevent overheating, creating a double bullish effect. Metrics like GDP, PMI surveys, and employment data are scrutinized as proxies for economic health. For example, consistently robust US jobs data reinforces growth and rate hike expectations, supporting the USD.

Inflation is the critical link between growth and interest rates. Moderate inflation is a sign of healthy demand, but high inflation erodes purchasing power and savings. Central banks have a mandate to control inflation, typically through interest rates. Therefore, rising inflation data (CPI, PCE) increases the probability of future rate hikes, which can be currency-positive. However, if inflation becomes unanchored and threatens economic stability, it can become currency-negative due to fears of damaging policy responses or loss of confidence.

Capital Flows represent the physical movement of money across borders. They are categorized as:

  • Trade Flows (Current Account): A country with a persistent trade surplus (exports > imports) sees a constant inflow of foreign currency which must be converted to the local currency, creating natural, structural demand.
  • Investment Flows (Financial Account): Includes Foreign Direct Investment (FDI) and portfolio investment (stocks & bonds). A country seen as a stable, high-growth destination will attract these flows.
  • Speculative Flows: Short-term capital moving to capture interest rate differentials (carry trades) or anticipated currency appreciation.

Institutional and Sovereign Activity exerts massive influence. Central banks themselves intervene directly in Forex markets to weaken or strengthen their currency for economic objectives. Sovereign wealth funds allocate billions globally, impacting currencies. Large multinational corporations engage in hedging operations that can create significant, predictable flows around month-ends and reporting periods.

Political Stability and Geopolitical Events underpin all other factors. Capital seeks safe, predictable jurisdictions. Political turmoil, corruption, or the threat of asset seizure can lead to capital flight and a collapsing currency, as seen in emerging market crises. Conversely, a nation perceived as a safe haven (like Switzerland or, at times, the US) will see its currency appreciate during global uncertainty, regardless of its interest rates.

In essence, the Forex market is a giant, continuous referendum on the relative economic and political fortunes of nations. The price of EUR/USD is the market's collective judgment on the future of the US economy versus the Eurozone economy, distilled into a single, fluid number. Understanding the hierarchy and interaction of these fundamental drivers—where interest rates sit at the apex for medium-term trends, supported by growth and inflation data, and occasionally overridden by geopolitical shocks—is the first step to mastering Forex fundamental analysis.

3. Economic Indicators Overview

Economic indicators are standardized statistical measurements released by government agencies, central banks, and private institutions that provide a snapshot of a country's economic performance. They are the vital signs of an economy—the pulse, blood pressure, and temperature that traders and policymakers monitor to diagnose health and predict future conditions. In the Forex market, these releases are not just data points; they are high-voltage events that can instantaneously recalibrate the market's perception of a currency's value by altering expectations for interest rates, growth, and capital flows.

Indicators exist because modern economies are too complex to understand anecdotally. They provide objective, quantifiable metrics that allow for comparison over time (Is inflation accelerating?) and across countries (Is US growth outperforming Eurozone growth?). They are constructed from vast surveys, tax records, and administrative data, compiled and seasonally adjusted to filter out predictable variations (like holiday shopping spikes).

The interpretation of an indicator hinges on three key values presented on every economic calendar: the Previous (last period's revised figure), the Forecast/Consensus (the median expectation of market economists), and the Actual (the just-released number). The market's reaction is driven almost entirely by the deviation of the Actual from the Forecast. A "good" number that was already fully expected (Actual = Forecast) often yields a muted or even counter-intuitive "sell the fact" reaction. A "bad" number that beats a very pessimistic forecast (Actual > Forecast) can trigger a rally. This dynamic makes understanding market sentiment and positioning as important as understanding the data itself.

Forex responds with such volatility to these releases for two main reasons: liquidity and leverage. The Forex market is decentralized and, during major data releases, order books can thin momentarily as market makers pull liquidity, leading to exaggerated price spikes. Furthermore, traders operate with high leverage. A small move triggered by data can result in disproportionate P&L swings, forcing rapid position adjustments that amplify the initial move.

Indicators are broadly categorized by their predictive quality:

  • Leading Indicators: Designed to predict future economic activity. They turn before the economy does. Examples include PMIs, building permits, and consumer confidence surveys. These are highly prized by traders as they offer early signals.
  • Coincident Indicators: Move simultaneously with the overall economy, providing a real-time assessment. Examples include GDP, industrial production, and retail sales.
  • Lagging Indicators: Change after the economy has already begun a trend, serving as confirmation. Examples include the unemployment rate and corporate profits.

The most powerful trading opportunities arise when a string of indicators begins to tell a consistent story that contradicts the prevailing market narrative or central bank guidance. For instance, if the market expects the Fed to pause, but consecutive reports on CPI, Retail Sales, and PMI all surprise to the upside, a dramatic repricing of rate expectations—and a sharp USD rally—is likely. Therefore, the skilled fundamental trader doesn't just trade one number in isolation but learns to weave individual data points into a coherent narrative about the economic cycle and policy response.

4. Interest Rates & Central Banks

The most powerful entity in the Forex universe is not a hedge fund or a sovereign wealth fund, but a nation's central bank. Central banks (the Federal Reserve, ECB, Bank of Japan, etc.) are the ultimate architects of a currency's medium-term destiny through their control of monetary policy. Their primary mandate is typically to ensure price stability (control inflation) and, often secondarily, to support maximum employment and sustainable growth. The tool they use to achieve this is the benchmark interest rate (e.g., the Fed Funds Rate, the ECB's Main Refinancing Rate).

The mechanism is foundational: Higher interest rates generally strengthen a currency, and lower rates weaken it. This occurs through two channels:

  1. The Capital Flow Channel: Higher rates offer a greater return on deposits and fixed-income securities denominated in that currency. This attracts foreign investment, requiring the purchase of the local currency.
  2. The Economic Channel: Higher rates cool an overheating economy and curb inflation. While this can be negative for growth assets, the direct yield advantage for the currency usually dominates in the Forex market.

However, central bank policy is not about the current rate but about the future path of rates. This is where the concepts of monetary policy cycles and forward guidance become critical.

  • Hiking Cycle: A central bank raises rates to combat rising inflation. The currency tends to appreciate most aggressively at the beginning of the cycle when the market is pricing in many future hikes. As the cycle matures, gains may slow or reverse if the bank signals a pause is near.
  • Cutting Cycle: A central bank lowers rates to stimulate a weakening economy. The currency tends to depreciate, with the most severe drops often occurring when the first cut is signaled or delivered.
  • Forward Guidance: This is the communication strategy central banks use to manage market expectations. Through statements, minutes, and speeches, banks telegraph their future policy inclinations. A shift from "we will be patient" to "we are prepared to act" is a major market-moving event.

Key central bank events every trader must watch:

  1. Interest Rate Decision
  2. Monetary Policy Statement
  3. Press Conference
  4. Meeting Minutes
  5. Speeches by Officials

Divergence is the core trading theme. The Forex market thrives on the difference in the speed and direction of monetary policy between two countries. For years after the 2008 crisis, a dominant trade was short EUR/USD based on the Fed moving toward tightening while the ECB was still in easing mode. A trader must therefore follow a comparative analysis: Which central bank is more hawkish (inclined to tighten)? Which is more dovish (inclined to ease)? Shifts in this relative stance create the most powerful and persistent trends in currency pairs.

5. Inflation Data (CPI, PPI)

Inflation is the primary focus of central banks and a supreme FX mover. Persistent high inflation erodes purchasing power and forces tighter policy.

CPI (and Core CPI) measure consumer price changes; Core excludes food/energy and best reflects the underlying trend.

  • Hotter-than-forecast Core CPI → higher rate expectations → stronger currency.
  • Revisions matter; watch MoM vs YoY dynamics.

PPI tracks producer prices and often leads CPI as input costs pass through.

  1. Release vs Forecast → surprise drives repricing
  2. Yields reprice (2Y most sensitive)
  3. FX follows yield attractiveness

6. Employment Data (NFP, Unemployment Rate, ADP)

A strong labor market is the bedrock of a healthy economy. It fuels consumer spending (a major share of GDP), supports government revenues, and gives central banks confidence to hike rates when combating inflation. Therefore, employment releases are among the most volatile and consequential events for Forex, especially the US Dollar.

Non-Farm Payrolls (NFP): First Friday monthly from the BLS; the king of indicators.

  • Why it matters: Timely, comprehensive gauge of US economic health; directly influences Fed policy.
  • Market reaction: Deviation from forecast drives USD moves; filtered by the current Fed narrative.

Unemployment Rate: Released with NFP; lagging but politically critical.

  • Dual mandate: Rising unemployment can prompt a dovish shift.
  • Nuance: Drops due to lower participation may temper positive reactions.

Average Hourly Earnings (AHE): Wage growth proxy and key inflation input.

  • Implication: Hot wages raise inflation risk → higher hike odds → USD positive (context-dependent).

ADP Employment: Private payroll estimate, two days before NFP.

  • Use: Adjusts expectations for NFP; correlation varies by regime.

Volatility pattern: At 8:30 AM ET, spreads widen, slippage risk spikes, and price can whipsaw: knee‑jerk on the headline, then a second move as details (AHE, unemployment, revisions) are parsed. Many pros avoid the first minutes and trade the confirmed direction once spreads normalize.

7. GDP & Economic Growth Metrics

Gross Domestic Product (GDP) is the broadest, most comprehensive measure of a nation's total economic output and health. It represents the total monetary value of all finished goods and services produced within a country's borders in a specific time period (quarter or year). In fundamental Forex analysis, GDP serves as the ultimate scorecard for economic performance, providing the long-term foundational trend upon which shorter-term interest rate and sentiment cycles play out.

GDP can be calculated using three approaches (which should sum to the same total):

  • Expenditure: GDP = C + I + G + (X − M)
  • Income
  • Production/Output

Key releases and why they matter:

  • Advance, Preliminary, Final: The first (Advance) is most market-moving.
  • Policy link: Strong growth can raise inflation risks and hike odds (FX positive); weak growth does the opposite.
  • Relative performance: FX is relative—divergent GDP trends across countries drive long-term pair trends.

Remember GDP is lagging; markets often anticipate with PMIs and other leading data. Big moves occur when GDP significantly deviates from expectations, forcing a reassessment of the narrative. Always examine the quality of growth (consumption/investment vs inventories/government) to judge sustainability.

8. Retail Sales, Consumer Confidence, and Spending

The consumer is the engine of most modern developed economies, accounting for 60-70% of GDP in countries like the United States, United Kingdom, and Australia. Therefore, data that reveals the health, mood, and spending habits of consumers is of paramount importance to Forex traders. It provides a real-time pulse on the largest component of economic activity and is a leading indicator for future GDP performance and inflationary pressures.

Retail Sales: This monthly report measures total receipts of retail stores. The Core Retail Sales figure (excluding autos) is a cleaner trend gauge.

  • FX impact: Strong retail sales suggest confident consumers and robust demand—supporting growth and potentially inflation (currency positive). Weak sales imply slowdown (currency negative).

Consumer Confidence/Sentiment: Survey-based measures (e.g., University of Michigan, Conference Board) of optimism/pessimism about finances and the broader economy.

  • Why it matters: A leading indicator for spending; rising confidence often foreshadows stronger retail sales and growth.
  • FX impact: Significant beats/misses can shift growth and rate expectations.

Institutions model consumer data (credit card spending, retail sales, confidence, wages) to forecast GDP components and inflation risk. Divergences across regions (e.g., resilient US consumer vs. faltering Eurozone consumer) reinforce relative FX biases.

9. Manufacturing Indicators (ISM, PMI)

Manufacturing indicators are leading barometers of economic health and often move FX before lagging data like GDP. They provide high-frequency, forward-looking insight.

PMI: Diffusion index; above 50 = expansion, below 50 = contraction.

US ISM Manufacturing: Watch New Orders, Production, Employment, Supplier Deliveries, and Prices Paid.

  • Timely (first business day), forward-looking (New Orders), inflation signal (Prices Paid).
  • Strong ISM with hot Prices Paid → hawkish path → currency positive; sub‑50 plunges → cut odds → currency negative.

10. Trade Balance & Current Account

A nation's trade balance and its broader sibling, the current account, measure the flow of goods, services, and income between a country and the rest of the world. They are fundamental to understanding long-term structural currency pressures, as they reveal whether a country is a net borrower or lender on the global stage.

Trade Balance: Exports minus imports.

  • FX link (direct): Buying exports requires converting into the local currency (demand). Paying for imports requires selling the local currency (supply). Persistent surpluses create ongoing currency demand; persistent deficits create supply.

Current Account: Trade balance plus net income from abroad and current transfers.

  • Surplus = net lender; reflects competitiveness and savings.
  • Deficit = net borrower; requires steady capital inflows to finance.

Deficits are not inherently currency-negative if confidently financed (e.g., deep capital markets attracting inflows). When confidence erodes, financing dries up and the currency must depreciate to restore balance. Watch monthly trade data for exporter currencies (AUD, CAD, NZD, JPY) and consider risk cycles: in risk-off, surplus currencies (e.g., JPY) tend to appreciate as capital is repatriated.

11. Forex Impact of Government Policies

Fiscal Policy: Stimulus (spending/tax cuts) boosts demand and can be currency positive via growth/inflation (and tighter policy). Austerity slows growth near-term (FX negative) but can improve long-term credibility (FX supportive).

Debt Sustainability: Rapidly rising debt-to-GDP and structural deficits can erode confidence, spark downgrades, and weigh on a currency.

Regulation & Stability: Market-friendly, predictable rules attract capital; sudden populist moves (capital controls, nationalization) drive outflows and depreciation.

Intervention: Authorities may buy/sell their currency to influence levels; short-term impact is large but sustained change requires policy alignment.

Sanctions/Policy Shocks: Sanctions, energy policy shifts, or trade regimes can structurally alter flows (e.g., energy for CAD/NOK). Combine fiscal with monetary stance for full FX picture.

12. Geopolitical Events & Their Effect on Forex

Wars, elections, trade wars, coups, sanctions, and diplomatic crises reshape risk perception and flows.

  • Risk-Off: USD/CHF/JPY bid; commodity & EM FX sold; gold and Treasuries gain.
  • Risk-On: Reversal—commodity & EM FX rally; safe havens soften.
  • Commodity shocks: Energy/food disruptions benefit exporters (CAD/NOK) and hit importers (JPY/EUR).

Liquidity thins during shocks; headlines drive whipsaws. Some events cause multi-year repricing (e.g., energy realignment in Europe). Align exposure with prevailing sentiment rather than chasing every headline.

13. Market Sentiment & Risk‑On/Risk‑Off Behavior

Market sentiment—the collective psychology of participants—drives powerful cross-asset flows that can override near-term fundamentals. In Risk‑On, investors seek yield; in Risk‑Off, they seek safety.

Risk‑On: Commodity and EM FX (AUD, NZD, CAD, NOK, MXN, BRL) appreciate; safe havens (USD, JPY, CHF) often weaken.

Risk‑Off: USD/JPY/CHF strengthen; commodity & EM FX sell off as carry is unwound.

  • Gauges: S&P 500 (equities), VIX (fear), US 10Y yields, DXY, AUD/JPY cross.
  • Use: Align trades with the prevailing regime; fade extremes when signals diverge.

14. News Trading Basics

News trading seeks to profit from volatility around high‑impact releases by trading the deviation of Actual vs Forecast. Execution risk is extreme due to spread blowouts, slippage, and fake‑outs.

  • Mechanics: Spreads widen; liquidity thins; stops can slip. Two‑stage moves: headline spike then digestion.
  • Approaches: Straddle (advanced), trade the detail after 30–90s, or fade overreactions.
  • Risk rules: Tiny size, hard stops, prefer limits, or avoid initial minutes and trade the aftermath.

15. High‑Impact News Events

Tier 1: Central bank decisions/pressers (Fed, ECB, BoJ, BoE, RBA, RBNZ, BoC, SNB), US CPI, NFP.

Tier 2: US Retail Sales, ISM/PMIs, GDP (Advance), EU CPI/GDP, China PMIs/GDP, OPEC+, major elections.

  • Pattern: calm → initial spike → digestion → new trend.
  • On FOMC: statement first; bigger move often during presser.

16. How to Read an Economic Calendar

An economic calendar lists scheduled releases (data, central bank events, speeches). Interpreting it is foundational.

  • Columns: Time/Date, Currency, Event, Impact, Actual, Forecast, Previous (revised).
  • The Deviation: Actual vs Forecast drives the move; revisions can amplify.
  • Context: Same print can mean different things depending on cycle and positioning.
  1. Mark high/medium impact for your pairs.
  2. Review recent trend and the prevailing narrative.
  3. Check correlated assets (DXY, yields, equities).
  4. Plan: trade it, hedge it, or stand aside. Define entries/stops/levels.

17. Correlations Between Currencies & Commodities

  • CAD ↔ Oil: Oil up → CAD tends to strengthen (USD/CAD down).
  • AUD ↔ Iron ore/Coal/Copper (China demand): Strong Chinese activity supports AUD.
  • NZD ↔ Dairy: GDT index is a key driver.
  • NOK ↔ Oil; ZAR ↔ Gold/PGMs: Export prices feed FX.
  • Gold vs USD: Typically inverse; both havens in different regimes.
  • DXY vs EUR/USD: Strong inverse correlation.

18. Currency Strength & Weakness Analysis

Assess currencies individually, then pair strong vs weak for clean trends.

  • Differentials: Compare policy stance, growth, inflation, fiscal health, political stability.
  • Strength indices: Use basket indices/meters to confirm broad performance.
  • Cross checks: Verify moves across many crosses to isolate the true driver.
  • DXY: Use as a proxy for broad USD to pick the cleanest pair.

19. Long‑Term vs Short‑Term Fundamental Analysis

Long‑Term (weeks–years): Identify secular trends from policy cycles, relative growth, and structural balances. Lower frequency, wider stops, position/swing style.

Short‑Term (minutes–days): Trade scheduled high‑impact data, speeches, and intraday sentiment shifts. High frequency, tight risk, execution‑sensitive.

Bridge: Use the long‑term bias for direction and time entries with short‑term catalysts and technical levels for confluence.

20. Combining Fundamentals with Technical Analysis

Fundamentals provide the why and direction; technicals provide the when and where. Trade only when both align to create confluence.

  • Bias → Map → Trigger: Set a fundamental bias, map HTF levels (S/R, trendlines, MAs), wait for catalyst‑validated price action at those levels.
  • Confirm breaks: Prefer breaks that occur on news consistent with your bias.
  • Filter trades: In a USD bull trend, buy dips rather than fight with shorts on minor negative prints.

21. How Institutions Trade Fundamentals

Banks, hedge funds, asset managers, corporates, and sovereigns dominate flows. They model data, parse guidance, and trade across spot, forwards, swaps, and options.

  • Process: Update policy‑probability models on each release; build positions gradually (VWAP), around liquidity.
  • Footprints: Sustained, high‑volume breaks often signal institutional participation; thin periods are dangerous.
  • Smart money traps: Liquidity hunts around obvious stops are common—place stops beyond crowded zones.

22. Dangers of News Trading & Volatility Spikes

  • Liquidity gaps & slippage: Market orders fill far from quotes during spikes.
  • Spread explosion: Costs jump 10–30+ pips on majors; stops slip.
  • Whipsaws & fake‑outs: Headline spike then reversal as details are parsed.

Rules: Tiny size, hard stops, use limits where possible, or avoid first minutes and trade the aftermath. Consider guaranteed stops if offered.

23. Examples of Real Fundamental Events & Market Reactions

  • NFP Shock & USD Rally (Jun 3, 2022): +390K vs +325K; hot labor kept Fed hawkish → yields up, USD surged; EUR/USD dropped >100 pips in minutes and trended lower for weeks.
  • SNB Floor Removal (Jan 15, 2015): Abolished EUR/CHF 1.20 floor → EUR/CHF collapsed ~30% in seconds; liquidity vanished; brokers and traders suffered extreme losses.
  • UK Mini‑Budget Crisis (Sep 2022): Unfunded tax cuts sank GBP to all‑time lows near 1.0350 as gilt yields spiked; fiscal credibility matters for FX.
  • ECB Hawkish Pivot (Jul 21, 2022): 50bps hike vs 25bps expected + new TPI tool → EUR rallied as divergence with Fed narrowed; guidance changes can flip trends.

24. Building a Fundamental Trading Plan

Step 1: Framework

  • Follow 2–3 major pairs. Track CB stance, growth (GDP/PMI), inflation (CPI), next key events.
  • Set a weekly bias (Bullish/Bearish/Neutral) per pair.

Step 2: Confluence Triggers

  • Enter only when fundamental bias aligns with HTF levels and a price action trigger.
  • Optionally align with a supporting data catalyst.

Step 3: Risk Rules

  • Fixed % risk (e.g., 1%); stops beyond invalidation; ATR‑aware sizing.
  • Profit plan: RR targets, partials, or trailing stops.
  • Event protocol: reduce/close before high‑impact releases or hedge.

Step 4: Journal & Review — Record thesis, trigger, outcome, lessons. Update the framework weekly.

25. Summary of Module 5

  • Relative game: FX prices one economy vs another.
  • Rates lead: Expected policy paths are the dominant medium‑term driver.
  • Macro triad: Growth, inflation, and employment shape policy and FX trends.
  • Regime shifts: Geopolitics, fiscal credibility, and sentiment can override data.
  • Best practice: Trade when fundamentals align with technicals under strict risk rules.