15. Dealing and Managing.

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The Best Execution (execution order) rules under COBS require firms to...
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... to execute orders on the terms which are most favourable to their client.
COBS sourcebook for Best Execution is split into three sections: COBS 11.2 (alternative investment fund managers, AIFM), COBS11.2A) MiFID investment firms) and...?
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COBS 11.2B UCITS management companies.
Undertakings for Collective Investment in Transferable Securities
Best Execution (execution order_. The execution factors are price, costs, speed, likelihood of execution, size or...
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nature (of execution order).
Best execution is not merely achieving the best price. For example, speed of execution could be less imporant than...
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... than likelihood of execution
Four-fold test determines whether...?
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... whether best execution applies by assessing legitimate reliance and firm discretion.
Firm discretion = swoboda decyzyjna firmy.
Nie każda transakcja oznacza, że firma ma obowiązek zapewnić best execution. Najpierw musi sprawdzić, czy w tej konkretnej transakcji klient rzeczywiście polega na firmie.
Four-fold test, first question:
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Did the investment firm initiate the transaction?
2. Does the client only ask you for a quote? |3. Will the client be unable to identify the relative levels of price transparency within a market? |4. Has the client confirmed that they place reliance with the investment firm?
Four-fold test, second question:
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Does the client only ask you for a quote (ie, it does not ‘shop around’ for quotes)?
1. Did the investment firm initiate the transaction? | 3. Will the client be unable to identify the relative levels of price transparency within a market? Has the client confirmed that they place reliance with the investment firm?
Four-fold test, a third question:
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Will the client be unable to identify the relative levels of price transparency within a market?
1. Did the investment firm initiate the transaction? | 2. Does the client only ask you for a quote? | Has the client confirmed that they place reliance with the investment firm?
Four-fold test, a four question:
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Has the client confirmed that they place reliance with the investment firm?
1. Did the investment firm initiate the transaction? 2. Does the client only ask you for a quote? 3. Will the client be unable to identify the relative levels of price transparency within a market?
Best Execution Where There are Competing Execution Venues. What is the requirement for a firm regarding a own comissions?
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A firm should not charge a different commission for execution in different venues.
Best Execution. Firms must ensure they review the Order Execution Policy on at least an annual basis or when...
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... when there are MATERIAL CHANGES that affect the firm’s ability to continue to obtain the best possible result for clients.
Order Execution Policies are for designated for MiFID investment businness and for...?
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... Non-MiFID Investment Business
No major differences. annually. Firms must NOTIFY both clients of any material changes. | Apropriate information needs to be more detailed for retail clients.
Portfolio managers, receivers, or transmitters of orders, must maintain order execution policies (like firms), byt they do not need to...
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... do not need to obtain consent.
Specific Client Instructions. Firms should adhere to the client’s instructions even if...
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... even if an alternative means of executing the order would have given a better result.
If instruction is partial, it override Execution Policy only in this relevant part.
Comparable client orders to be executed in the order in...
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in which they are received.
Unless this is impracticable.
Firms must only aggregate their deals with those of a client, or aggregate two or more clients’ deals, this is unlikely to disadvantage any of the aggregated clients and
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... this is unlikely to disadvantage any of the aggregated clients
... the fact that aggregation may work to their disadvantage is disclosed to the clients.
If a firm has its own-account orders aggregated it must allocate the client orders in priority over its own, unless...
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... unless it can show that, without the inclusion of its own order, less favourable terms would have been obtained.
A firm which receives a client limit order for listed shares and which cannot immediately execute it under the prevailing market conditions must make the limit order...
Limit order = zlecenie z limitem ceny (minimalnej, czy maksymalnej).
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... public. This should be done immediately.
transmitting the order to a regulated market or MTF (Multilateral Trading Facility).
A firm which receives a client limit order for listed shares and which cannot immediately execut must make the limit order public. However, The firm need not do so, however, for
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... for orders over normal market size.
Firms must have arrangements in place to prevent their employees who are relevant persons (directors, partners, appointed representatives, other) entering into a personal transaction that is contrary to...
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to UK MAR,
which involves misuse of confidential information,
Firms must have arrangements in place to prevent their relevant persons from improperly advising or...
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procuring that anyone else enters into a transaction.
Firms must have arrangements in place to prevent their relevant persons from improperly DISCLOSING any information that as a result the other person will to take either of the following steps to...
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... enter into a transaction in designated investments
or advise or procure another person to enter into such a transaction.
The rules on personal account dealing do not apply to |personal transactions in life policies, |and deals in units in certain classes of fund (UCITS, OEICs or unit trusts) | and to...
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... deals under a discretionary management service.
deals in units in certain classes of fund (UCITS, OEICs or unit trusts), | personal transactions in life policies.
The rules on personal account dealing do not apply to |personal transactions in life policies, | and deals under a discretionary management service| and to...
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... deals in units in certain classes of fund (UCITS, OEICs or unit trusts).
deals under a discretionary management service, | personal transactions in life policies.
The rules on personal account dealing do not apply to | deals under a discretionary management service, | and to deals in units in certain classes of fund (UCITS, OEICs or unit trusts) | and to...
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... personal transactions in life policies.
deals under a discretionary management service, | deals in units in certain classes of fund (UCITS, OEICs or unit trusts).

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