The FCA introduced rules in January 2018 as a response to the requirements of the EU Markets in Financial Instruments Directive II (MiFID II), which require JM Finn, because it executes and transmits client orders, to summarise and make public on an annual basis, for each class of financial instrument the top five execution venues in terms of trading volumes where we have executed or transmitted client orders in the preceding calendar year.
We are also required to publish information on the quality of execution obtained. This report is intended to provide clients with a better understanding of our analysis and the conclusions we have drawn from our monitoring of our trading activities.
We published the order execution tables for the first time in April 2018. The information published was on a best endeavours basis as the FCA understood that firms, such as ourselves, would be unlikely to have the IT systems in place to process all of the information required.
From April 2019 we will publish the previous year’s data and our analysis on the quality of execution obtained in full.
Order Execution tables
The tables available via the links below set out the top five execution venues used by JM Finn in the relevant year. We have broken the information down to show executed orders, which is where our dealing desk have carried out transactions in UK instruments, and transmitted orders where we use external firms such as third party brokers to carry out transactions in overseas instruments. These two areas have been further split by asset type, as indicated in the heading of each table and further again by retail and professional client type. We have only included data tables for asset classes that JM Finn is active in.
We are not able to include data for trades that have been amended as a result of an error with the quantity, price, counterparty, time of trade or venue code input into the system when carrying out orders. Such amendments only accounted for 0.2% of orders for 2018. Therefore, to the best of our knowledge, we believe the data to be a fair and accurate reflection of our top five execution venues.
The data in these tables, amongst other information, sets out the percentage of passive and aggressive orders. A passive order can be viewed as one that adds liquidity to the market (where a price has been set at which the order must be done rather than accepting the price available in the market, or a large order that needs to be worked patiently over time). An aggressive order can be viewed as one that takes liquidity from the market (where the price that is available is accepted). This data is not relevant to transmitted business and so has been left blank. Please note that we revised our data tables and reposted on 5th June 2019. This was in response to new guidance published by European Securities and Markets Authority (ESMA) on 29th May 2019 on the treatment of passive and aggressive orders in relation to quote driven trading systems.