MiFID II RTS 28 – Annual Best Execution Disclosure 2017
1st January 2017 through until 31st December 2017
Top 5 Brokers and Top 5 Venues
Quality of Execution Statement (Professional Clients Only)
PLEASE NOTE THAT THE FOLLOWING FIGURES RELATE TO FLOW FROM PROFESSIONAL CLIENTS ONLY*
Reception and Transmission of Orders Top 5 Brokers
Class Of Instrument |
Contracts for Difference |
|
Notification if <1 average trade per business day in the previous year |
N |
|
Top five execution brokers ranked in terms of trading volumes (descending order) |
Proportion of volume traded as a percentage of total in that class |
Proportion of orders executed as percentage of total in that class |
CFH Clearing Ltd. |
100% |
100% |
LMAX |
0 |
0 |
* The above information only refers to GMI’s clients who have been categorised as “Professional Clients” as per section 3.5 of Conduct of Business Sourcebook (COBS) of the FCA Handbook.
Please note the above information does not reflect the reception and transmission of orders by GMI’s clients who have been categorised as “Eligible Counterparties” as per section 3.6 of Conduct of Business Sourcebook (COBS) of the FCA Handbook.
PLEASE NOTE THAT THE FOLLOWING FIGURES RELATE TO FLOW FROM ELIGIBLE COUNTERPARTIES (SUCH AS BROKERS AND OTHER LARGE FINANCIAL INSTITUTIONS ONLY)*
ELIGIBLE COUNTERPARTIES
Reception and Transmission of Orders Top 5 Brokers
Class Of Instrument |
Contracts for Difference |
|
Notification if <1 average trade per business day in the previous year |
N |
|
Top five execution brokers ranked in terms of trading volumes (descending order) |
Proportion of volume traded as a percentage of total in that class |
Proportion of orders executed as percentage of total in that class |
DISCLOSURE NOT REQUIRED |
Please note that GMI does not disclose the reception and transmission of orders by its clients who have been categorised as “Eligible Counterparties” as per section 3.6 of Conduct of Business Sourcebook (COBS) of the FCA Handbook.
Summary of Information
GMI publishes for each class of financial instruments, a summary of the analysis and conclusions they draw from their detailed monitoring of the quality of execution obtained on the execution venues where they executed all client orders in the previous year. The information is as follows:
The execution factors below refer to the considerations and choices which GMI accounted for when it dealt with the client when we owed the client a regulatory duty of best execution:
GMI generally gave the highest priority to the total consideration, factoring in the size, nature and type of characteristics of the order when representing the price of the product and the costs relating to execution. The Best Execution Approach is the same for all types of financial instrument in respect of which GMI owes a duty of best execution.
There are no close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.
There is no specific arrangements or non-monetary benefit with any of the LPs GMI is working with.
No changes have occurred.
The execution factors for Best Execution purposes differed depending on the client’s MIFID II classification. GMI does not deal with retail clients as per the scope of permissions. For professional clients a wider range of execution factors were taken into account as listed above in a). GMI does not owe a duty of Best Execution to eligible counterparties (ECPs).
GMI does not deal with retail clients as per the scope of permissions.
GMI monitor pricing, spreads, liquidity and speed of execution, using active management to ensure the end result for the client is the best available.