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Order Execution – RTS 28

The European Securities and Markets Authority (ESMA) requires investment firms to publish, on an annual basis, information on the identity of execution venues and the quality of execution obtained.  This reporting requirement falls under the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”).

RTS 28 supplements the Directive by outlining the requirements designed to increase transparency related to executing client orders on trading venues, including systematic internalisers, market makers or other liquidity providers, with the aim of improving investor protection.

To adhere to RTS 28, BTIG Limited is required to “publish for each asset class of financial instruments, a summary of the analysis and conclusions it draws from its detailed monitoring of the quality of the execution obtained on the execution venues where they executed all client orders in the previous year”.

BTIG Limited’s RTS 28 analysis for period 3 January to 31 December 2019 is available here.

A. Execution Factors

Achieving the best possible result for our client will depend on the characteristics of the Order and the trading environment at the time of the Order. Subject to any specific instructions that may be given by the client, when executing orders we will take all sufficient steps to obtain the best possible result for our Clients considering the Execution Factors listed below:

  • Price
  • Costs payable by the client as a result of execution
  • Speed of execution and settlement
  • Likelihood of execution and settlement
  • Size of the transaction
  • Nature or any other consideration relevant to of the execution of the Order

In accordance with BTIG’s Best Execution and Order Handling Policy, price and cost will usually merit a high relative importance in obtaining the best possible result for clients.  However, for some clients, orders, financial instruments, or markets, we may appropriately determine that other Execution Factors are more important than price in obtaining the best possible execution result, for example, when trading in emerging markets.

B. Close links, conflicts of interest and common ownership

BTIG does not have any conflicts of interest with respect to execution venues used to execute orders.  We do have close links and a common ownership with BTIG LLC (U.S based) and BTIG Hong Kong Limited which are affiliate companies.  We direct orders to these entities to gain access to local markets leveraging their exchange memberships and market expertise.

C. Arrangements with execution venues regarding payments

BTIG does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

D. Factors leading to a change in the list of execution venues listed in the firm’s execution policy

As a firm we utilise a portfolio of investment banks Direct Market Access (DMA) and algorithms to execute our orders.  The reasons for this are twofold:  Firstly, it allows us access to a greater depth of liquidity and execution venues, and we monitor closely the efficiency of each investment bank and their sub-venues in our monthly TCA reviews.  Secondly, it allows us to carry on with “business as usual” should one of our investment bank venues suffer an outage for any period of time.

During summer 2019, one of the investment banks we used for execution decided to cease its equities business and has been removed from our list.

E. Client categorisation

BTIG’s clients are predominantly categorised as Professional Clients, with a small number of ECPs.  Our clients are all institutions, the majority of which are regulated entities.

F. How BTIG has used any data or tools relating to the quality of execution

The quality of execution obtained from our execution venues is monitored on a daily basis.  We are satisfied we have complied with our Execution and Order Handling Policy in seeking to obtain the best possible result for our clients on a consistent basis.

Since 3 January 2018, we have required our execution venues to provide us with TCA reports on a monthly basis, which are reviewed in addition to our own internal TCA monitoring system.