MIFID II RTS 28 Reporting
MIFID II RTS 28 Reporting
Top five execution venue by volume and quality
Under the Regulatory Technical Standards (RTS) 28 of the Directive 2014/65/EU, Hamilton Court FX LLP (HCFX) is required to publish on an annual basis the top five execution venue by trading volume for each class of financial instruments. Furthermore, HCFX is obliged to disclose information regarding to the quality of these executions.
Quality of execution:
HCFX aims to achieve the best possible transaction results for its clients and takes all reasonable steps to accomplish this. All clients are treated equally and trades are executed in accordance with HCFX’s Execution Policy. The adherence to this policy by the firm and all of its employees is monitored on an on-going basis by the Compliance function.
HCFX trades only with Professional Clients, therefore the published data relates to this clients class only. When we receive no specific instructions from the client in regards of the trade execution, HCFX considers the price/cost to be the main factor of execution. Additionally, any other factors (e.g. speed of execution, capacity of execution size and nature of the order), which are deemed relevant to the transaction are taken into consideration. The importance of these additional factors are measured on a trade to trade basis.
HCFX has no conflict of interest or any specific arrangement (e.g. discounts or non-monetary benefits) with any execution venues used to execute orders.
HCFX offers a single class of financial instrument, which is currency derivatives. The table below includes all trades of futures, options, swaps and forwards executed in the period between 1st of January and 31st of December 2018.
Top five execution venue for Professional clients:
|Class of Instrument||Currency derivatives|
|Notification if < 1 average trade per business day in the previous year||Y|
|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||Percentage of passive orders||Percentage of aggressive orders||Percentage of directed orders|
|Barclays Bank Plc (G5GSEF7VJP5I7OUK5573)||68.01%||68.01%||n/a||n/a||0%|
|Nomura International Plc (DGQCSV2PHVF7I2743539)||31.99%||31.99%||n/a||n/a||0%|
Definitions used in this report:
- Currency derivates: Futures, options, swaps, forwards and other currency derivatives admitted to trading on a trading venue.
- Professional clients: Institutional investors, including investment firms and credit institutions. The term ‘Professional clients’ includes both per se and elective professional clients.
- Passive order: an order entered into the order book that provided liquidity. This is not applicable as HCFX does not operate an order book.
- Aggressive order: an order entered into the order book that took liquidity. This is not applicable as HCFX does not operate an order book.
- Directed order: an order where the client has specified an execution venue for the order, prior to execution.
- Volume traded: HCFX interprets the volume of trade as the notional value attached to that specific trade.
 All definitions are set by the Directive 2014/65/EU of the European Parliament and of the Council. This can be accessed online at http://ec.europa.eu/finance/securities/docs/isd/mifid/rts/160608-rts-28_en.pdf .
In 2018 Hamilton Court Foreign Exchange Limited has assumed all assets and liabilities in respect of Hamilton Court FX LLP, and so these disclosures remain accurate despite the change of legal status which occurred during this time.