MiFID II

What are MiFID and MiFID II?

Prompted by changes in the way financial markets operate, in 2007 the European Commission introduced the Markets in Financial Instruments Directive (MiFID) with the aim of creating a level playing field in the European Economic Area (EEA).

The further MiFID II reforms, effective from January 2018, mean that organised trading of financial instruments had to move to multilateral and regulated trading platforms or be subject to transparency requirements where traded over-the-counter (OTC). Strict transparency rules also ensure that dark trading of shares and other equity instruments which might undermine efficient and fair price formation are no longer allowed.

Best Execution

Under MiFID and MiFID II, with effect from 3 January 2018, Credere Capital LLP is required to take sufficient steps to obtain the best possible result for its clients when executing orders on their behalf. In order to detail our approach, we include below the Best Execution Policy that complies with this MiFID II obligation.

MiFID II stipulates that we act in the best interests of clients when providing execution services and maintain monitoring arrangements that demonstrate compliance. Credere must also make disclosures to allow clients to make informed choices between competing dealers by publishing reports (under RTS 28) on execution venue selection.


Final Credere BestEx Policy June 2019.pdf

MIFID II Disclosures

Credere Capital LLP accepts the MiFID II best execution regulation and achieves this by dealing with a wide range of regulated counterparties in an attempt to achieve the best price for the fund. It should be noted that the transactions are mostly net and OTC and that the nature of the equity/bond paired transactions mean that there are no obvious data comparisons available. Further, most trades are executed on a relative value basis so a simple comparison against absolute price is not appropriate.

In accordance with COBS 11.2A.39 R, Credere are required to published the top 5 execution venues in terms of trading volumes for all executed client orders per class of financial instruments and also information on the quality of execution obtained.

Top 5 Execution Venues:

Class of Financial Instrument

Name of Broker or Counterparty

Equities

GS EMSX

FX Derivatives

Barclays NY

Bonds

Nomura

Goldman Sachs

JP Morgan


Credere Capital LLP is authorised and regulated by the Financial Conduct Authority in the UK (register number 713367). © Trium Capital LLP.