Regulatory Information

Order Execution Policy

If you are a client of any kind or institution or fund or trustee or corporate entity requesting us to deal or trade in securities and financial instruments on your behalf or (with appropriate authority) on behalf of a third party, it is important that you read this policy as we will deem that you agree to the terms of the policy and our Dealing Policy when you request us to act on your behalf.

All instructions are acted upon at our sole discretion and we may refuse to accept any dealing instruction without giving a reason. We draw your attention in this regard to regulatory rules on tipping off where, for example, we may suspect financial crime or where we are acting upon the instructions of proper authorities such as regulators or law enforcement agencies. 

Reyker’s order execution policy complies with the Markets in Financial Instruments Directive (“MiFID”) and will or may be revised as appropriate for early adoption of MiFID II and the associated regulation MiFIR, which are scheduled to come into force on 3 January 2018.  Reyker treats all clients fairly. Part of our method of achieving this is through our Order Execution Policy that is summarised here and which we will abide by when handling any standard dealing instructions from investors or instructing parties. 

Our Order Execution Policy must be read in the context of our Dealing Policy and our Conflict of Interest Policy, and our General Terms and Conditions of Business, all of which are usually available in their most up to date forms on our website  The most up to date versions that we have published always apply.  FCA regulatory rules and appropriate legislation and relevant European Union directives (or UK equivalents) also apply. We may update or amend our Order Execution Policy at any time and without notice for reasons of compliance and risk management or any appropriate commercial purpose and any such amendment will supersede previous policies. 

When you instruct or request us to buy or sell an investment we will consider the following factors when determining the best way of placing the deal for you. Please note that the MiFID order execution policy framework is considered when undertaking deals or trades for all client classifications, including retail, professional and institutional. 

The FCA require firms to take all reasonable steps to obtain, where executing orders, the best possible result for its clients taking into account the execution factors summarised below:

  • Your client classification
  • The characteristics of the instrument
  • Price, cost, speed and likelihood of execution and settlement
  • The type of order, its size and its nature
  • The execution venues on which it can be dealt
  • Whether there is a liquid market for the instrument
  • Plus, any other factors that we are aware of or are made aware of that seem to us to be relevant to the execution of the order request or instruction.

We will determine in our sole judgement the relative importance of these factors by using Reyker’s dealing policy, commercial judgement and experience in the light of market information available and by considering any other execution factors. Best execution judgements are determined by us by reference to information available to us at the time of trade or just before the time of trading. Hindsight is not pertinent to this where factors were not apparent or available to us, or when clients or instructing parties withhold relevant or potentially relevant information from us. 

Reyker acknowledges that price will ordinarily merit a higher relative importance in obtaining the best possible result. This, however, should not be considered the sole determining factor. In some circumstances, for some clients, speed, likelihood of execution and settlement, the size and nature of the order, market impact and any other implicit transaction costs may be given precedence over the immediate price and cost consideration only insofar as they are instrumental in delivering the best possible result in terms of the total consideration of the order.

We also remind clients that we only execute any order or instruction when irrevocably cleared funds are available in your account with us to cover both the proposed transaction and all fees and costs, or we hold realisable assets that can be traded to fund a transaction through a realisation trade (for which dealing charges apply), or where we have made other arrangements in writing in advance with you to provide finance or adjust the settlement timescale. We do not necessarily allow any trade that creates an overdrawn account (stock balances over which we hold a lien are not taken into account in determining overdrawn accounts as client assets and client money are accounted for under different FCA rules) unless we have previously agreed a facility with you in writing and we will make charges for all unauthorised overdrawn positions that occur or arise as a result of any instruction that you give us.  We may also refuse to accept any trade that creates or may create an overdrawn account.