RTS 28 DISCLOSURE
Execution model Requirements under Article 3(3)
In accordance with the requirements of the Markets in Financial Instruments Directive (MiFID II), investment firms that execute client orders are required to summarise and publish the top five execution venues based upon trading volumes for each class of financial instrument in the preceding year, as well as information on the quality of execution obtained. This information is based upon the average daily number of trades over the period. GPIM’s RTS 28 report is for the period 2nd January 2019 to 31st December 2019.
RTS 28 Report – December 2019
We have included tables that display the top 5 execution venues currently used by GPIM Limited, to execute all client orders. The table is provided in the layout as required by the Commission Delegated Regulation (EU) 2017/576 of 8 July 2016 (regulatory Technical Standard (RTS) 28).
We have summarised below the information regarding GPIM Limited’s execution practices. GPIM Limited operates under a Model B clearing arrangement with Third Financial and Third Financial may execute bargains on our clients’ behalf and they may process orders on our behalf.
Requirements Under Article 3(3)
- An explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution;
- A description of any close links, conflicts of interest, and common ownerships with respect to any execution venues used to execute orders;
- A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;
- An explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred;
- An explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements;
- An explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client;
- An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];
- Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider.
GPIM Response;
The factors that are most important in the achievement of best execution are price and size, these factors are heavily dependent upon each other as the price will be affected by the size of any intended transaction. Speed and likelihood of execution have similar impacts on the price achievable and speed may have a direct correlation to size depending upon the particular circumstances prevalent at the time.
GPIM Response;
GPIM limited does not have any common ownerships, close links or conflicts of interest in regard to any execution venues.
GPIM Response;
GPIM Limited does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.
GPIM Response;
The firm regularly monitors and reviews the list of firms available as execution venues; it actively seeks new venues.
GPIM Response;
The execution policy treats all clients in the same manner.
GPIM Response;
No other criteria are given precedence over immediate price and cost when executing retail client orders.
GPIM Response;
The firm regularly monitors the quality of execution obtained from the venues used.
GPIM Response;
This is not applicable.
GPIM Limited RTS 28 Table
Table 1- Retail Client Template | ||
Class of Instrument | Equities 02.01.19 – 31.12.19 | |
Notification if <1 average trade per business day in the previous year | No | |
Top five execution venues 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 |
Winterflood Securities Limited 8BRUP6V1DX3PIG2R0745 | 30.35 | 36.48 |
N+1 Singer Cap Markets 213800ITO7QMNQ9SFG53 | 17.71 | 17.34 |
Arden Partners 213800KRNTZFOY1DA806 | 17.25 | 5.02 |
Peel Hunt 5493007DWN0R4YBM4C84 | 9.84 | 14.19 |
Liberum Capital 213800U6KUF87S1KCC03 | 8.02 | 10.74 |
GPIM Limited doesn’t interact with the order book and clients do not specify execution venue | ||
Table 1- Retail Client Template | ||
Class of Instrument | Bonds 02.01.19 – 31.12.19 | |
Notification if <1 average trade per business day in the previous year | No | |
Top five execution venues 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 |
Winterflood Securities Limited 8BRUP6V1DX3PIG2R0745 | 99.68 | 10.53 |
Liberum Capital 213800U6KUF87S1KCC03 | 0.32 | 89.47 |
GPIM Limited doesn’t interact with the order book and clients do not specify execution venue |
Execution model Requirements under Article 3(3)
In accordance with the requirements of the Markets in Financial Instruments Directive (MiFID II), investment firms that execute client orders are required to summarise and publish the top five execution venues based upon trading volumes for each class of financial instrument in the preceding year, as well as information on the quality of execution obtained. This information is based upon the average daily number of trades over the period. GPIM’s RTS 28 report is for the period 2nd January 2019 to 31st December 2019.
RTS 28 Report – December 2019
We have included tables that display the top 5 execution venues currently used by GPIM Limited, to execute all client orders. The table is provided in the layout as required by the Commission Delegated Regulation (EU) 2017/576 of 8 July 2016 (regulatory Technical Standard (RTS) 28).
We have summarised below the information regarding GPIM Limited’s execution practices. GPIM Limited operates under a Model B clearing arrangement with Third Financial and Third Financial may execute bargains on our clients’ behalf and they may process orders on our behalf.
Requirements Under Article 3(3)
- An explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution;
- A description of any close links, conflicts of interest, and common ownerships with respect to any execution venues used to execute orders;
- A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received;
- An explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred;
- An explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements;
- An explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client;
- An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27];
- Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider.
GPIM Response;
The factors that are most important in the achievement of best execution are price and size, these factors are heavily dependent upon each other as the price will be affected by the size of any intended transaction. Speed and likelihood of execution have similar impacts on the price achievable and speed may have a direct correlation to size depending upon the particular circumstances prevalent at the time.
GPIM Response;
GPIM limited does not have any common ownerships, close links or conflicts of interest in regard to any execution venues.
GPIM Response;
GPIM Limited does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.
GPIM Response;
The firm regularly monitors and reviews the list of firms available as execution venues; it actively seeks new venues.
GPIM Response;
The execution policy treats all clients in the same manner.
GPIM Response;
No other criteria are given precedence over immediate price and cost when executing retail client orders.
GPIM Response;
The firm regularly monitors the quality of execution obtained from the venues used.
GPIM Response;
This is not applicable.
GPIM Limited RTS 28 Table
Table 1- Retail Client Template
Class of Instrument:
Equities 02.01.19 – 31.12.19
Notification if <1 average trade per business day in the previous year:
No
Top five execution venues ranked in terms of trading volumes (descending order):
Winterflood Securities Limited 8BRUP6V1DX3PIG2R0745
Proportion of volume traded as a percentage of total in that class: 30.35
Proportion of orders executed as percentage of total in that class: 36.48
N+1 Singer Cap Markets 213800ITO7QMNQ9SFG53
Proportion of volume traded as a percentage of total in that class: 17.71
Proportion of orders executed as percentage of total in that class: 17.34
Arden Partners 213800KRNTZFOY1DA806
Proportion of volume traded as a percentage of total in that class: 17.25
Proportion of orders executed as percentage of total in that class: 5.02
Peel Hunt 5493007DWN0R4YBM4C84
Proportion of volume traded as a percentage of total in that class: 9.84
Proportion of orders executed as percentage of total in that class: 14.19
Liberum Capital 213800U6KUF87S1KCC03
Proportion of volume traded as a percentage of total in that class: 8.02
Proportion of orders executed as percentage of total in that class: 10.74
GPIM Limited doesn’t interact with the order book and clients do not specify execution venue
Table 1- Retail Client Template
Class of Instrument:
Bonds 02.01.19 – 31.12.19
Notification if <1 average trade per business day in the previous year:
No
Top five execution venues ranked in terms of trading volumes (descending order):
Winterflood Securities Limited 8BRUP6V1DX3PIG2R0745
Proportion of volume traded as a percentage of total in that class: 99.68
Proportion of orders executed as percentage of total in that class: 10.53
Liberum Capital 213800U6KUF87S1KCC03
Proportion of volume traded as a percentage of total in that class: 0.32
Proportion of orders executed as percentage of total in that class: 89.47
GPIM Limited doesn’t interact with the order book and clients do not specify execution venue
GPIM Limited is an investment management firm whose registered office is at 727-729 High Road, London, England N12 0BP and is registered in England and Wales no. 10765547 VAT registered GB 274 0497 90.
GPIM is authorised and regulated by the Financial Conduct Authority (FCA) and is a member of the London Stock Exchange.
GPIM Limited is an investment management firm whose registered office is at 727-729 High Road, London, England N12 0BP and is registered in England and Wales no. 10765547 VAT registered GB 274 0497 90. GPIM is authorised and regulated by the Financial Conduct Authority (FCA) and is a member of the London Stock Exchange.
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