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EXECUTION RULES
INTRODUCTION
This document sets out the policy of TTCM TRADERS TRUST CAPITAL MARKETS LIMITED ("the Company") to take all reasonable steps to obtain the best possible result for its retail and professional Clients when receiving and transmitting Orders for execution in relation to Financial Instruments on behalf of the Client.
Following the implementation of the Markets in Financial Instruments Directive (MiFID) in the European Union and in accordance with the Investment Services and Activities and Regulated Markets Law of 2007 (Law 144(I)/2007) in Cyprus, the Company is required to provide its Clients and potential Clients with its Order Execution Policy ("the Policy").
DEFINITIONS
"Financial Instruments" shall mean Foreign Exchange and Financial Contracts for Difference.
"Order" shall mean an instruction to buy or sell a Financial Instrument which is accepted by the Company for transmission to a third party.
"Execution Venue" means a market maker, or other liquidity provider or entity that performs a similar function in a third country to the function performed by any of the foregoing.
"Execution Factors" shall mean those factors listed in paragraph 3 of this Policy.
"Execution Criteria" shall mean those factors listed in paragraph 5 of this Policy.
"Multilateral Trading Facility ("MTF")" shall mean a multilateral system, operated by an investment firm or a market operator, which brings together multiple third party buying and selling interest in Financial Instruments and in a way that results in a contract in accordance with MiFID.
SCOPE
This Policy applies where the Company receives and transmits Client's Orders in respect of retail and professional clients for execution for the following Financial Instruments:
Foreign Exchange and Financial Contracts for Differences.
EXECUTION FACTORS
The Company will take into account the following Execution Factors in order to obtain the best possible result for the Clients:
The price;
The costs;
The speed of execution;
The likelihood of execution;
The likelihood of settlement;
The size of the Order;
The market impact.
This list is not exhaustive. These factors are explained in detail in the Business Terms of the Company approved by the Client prior to transmitting Orders for execution.
SPECIFIC INSTRUCTIONS
Where the Client provides the Company with a specific instruction in relation to his/her Order or any part of it, including selection of Execution Venues, the Company will transmit that Order for execution in accordance with those specific instructions and, in doing so, the Company will have complied with its obligations to provide the best possible results to the extent that those instructions are followed.
However, the Company would like to warn Clients that any specific instruction may prevent the Company from taking the steps that have been designed and implemented in the Policy to obtain the best possible result for the execution of those Orders in respect of the elements covered by such instructions.
EXECUTION CRITERIA
The Company will take into account the following Execution Criteria when transmitting a Client's Orders:
The characteristics of the client including the categorization of the Client as retail or professional;
The characteristics of the Order of the Client;
The characteristics of the Financial Instruments that are subject to that Order;
The characteristics of the Execution Venue to which that Order can be directed.
For a retail Client's Order, the Company will take into consideration all factors that will allow the Company to deliver the best possible result in terms of the total consideration, representing the price of the Financial Instrument and the costs related to the execution including all expenses incurred by the Client which are directly related to the execution of the Order, such as Execution Venue fees, clearing and settlement fees, and any other fees paid to third parties involved in the execution of the Order.
Where there is more than one available Execution Venue for the execution of an Order, the commissions and the costs of the Company for transmitting the Order on each of the eligible Execution Venues shall be taken into account when assessing and comparing the results for the Client that would be achieved by executing the Order on each of the eligible Execution Venues.
The Company undertakes not to structure or charge its commissions in such a way as to discriminate unfairly between Execution Venues.
EXECUTION VENUES
Execution Venues are the entities to which the Company transmits Orders for execution.
We will regularly assess the Execution Venues available in respect of any products that the Company provides to its Clients to identify those that will enable the Company, on a consistent basis, to obtain the best possible result when transmitting Orders for execution.
The Client acknowledges that the transactions entered into with the Company in Foreign Exchange and Financial Contracts for Difference are undertaken through the trading platform of the Company. The Orders will be executed on an 'over the counter' basis rather than on a regulated market or a Multilateral Trading Facility. Such Orders are automatically routed to an Execution Venue which we have assessed to be the best execution.
In case of technical failure of the trading platform or quote feeds, the Company may not transmit the Order for execution or it may change the opening/closing price of an Order.
Under certain market conditions such as a fast moving market or low liquidity, the Company reserves the right to modify the spread of the transactions.
In certain circumstances such as unusual market conditions or the size and nature of the Client's Order, it may be wholly or partly manually priced and/or an Order may be manually transmitted for execution, and then have an impact on the price at which the Order is executed.
ORDERS-INSTRUCTIONS
Once the Client's instructions or Orders are given to the Company, they cannot be revoked.
The Client requests a quotation at the price that is stated on the Company's trading platform. However, due to the high volatility of the market, prices may change before a Client can execute at their determined price. The Company at this point, has the right to offer the Client a new price. The Client can either accept the new price and execute the order, or refuse the new price, cancelling the order transaction completely.
Orders can only be placed, executed, modified or closed within the trading time and shall remain effective through to the next trading session. The Client's order shall be valid according to the type and time of the given order. If the time of validity of the order is not specified, it shall be valid indefinitely.
Order status is always shown on the client's online trading platform. Should access to the online trading platform not be possible, Clients may contact the Company by telephone and request the status of any of their pending orders.
Certain types of orders (Stop loss, Stop limit, Take Profit, Buy Limit, Buy Stop, Sell Limit, Sell Stop) which restrict the maximum amount of losses, may turn out to be inefficient under certain trading conditions, where the market situation may make the execution of such orders impossible. Such a situation could arise due to high volatility of the market, where rapid price movement could cause the price to rise or fall, preventing an order from being executed at the stipulated price.
MONITORING
The Company will review and monitor the effectiveness of this Policy on a regular basis, and at least annually, in order to identify any deficiencies and implement any appropriate enhancements. The Company will also review whether the Execution Venues and the entities chosen by the Company to transmit Orders for execution continue to provide the best possible result for the Clients on a consistent basis.
We will notify the Client of any material change to this Policy by posting an updated version on the website.
CLIENT CONSENT
The Company is required to obtain the Client's prior consent to this Policy prior to transmitting Orders for execution. Furthermore the Company is also required to obtain the Client's prior express consent before transmitting his Order for execution outside a regulated market or a Multilateral Trading Facility (MTF). The Company may obtain the above consent in the form of a general agreement.
This Policy forms part of the Business Terms and the Client's consent will be deemed to be provided when the Client consents to our Business Terms.
This policy is applicable from January 1st, 2010 and shall remain effective until a more recent version is released.
