CdR Capital Ltd (“CdR”) is authorised and regulated by the Financial Conduct Authority (“FCA”). Under the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”), it is required to publish on its website, annually, information on its top five execution trading venues and brokers, by trading volume, as well as information regarding the quality of execution received – in accordance with Regulatory Technical Standard 28 (“RTS28”).

This best execution disclosure is for the calendar year 1 January 2020 to 31 December 2020 (“period”). Note that CdR is required only to make this disclosure in respect of its MiFID activities.

The annual top five broker and venue disclosures are made separately for indirect execution and direct execution. Indirect execution refers to situations where CdR has placed orders with an entity such as a broker and then the broker executes the order). Direct execution refers to situations where CdR has directly executed a client order, such as with a counterparty, or on a venue without passing through a broker’s order management system. 

CdR uses Direct Electronic Access (“DEA”) providers to act as a market participant or trading venue member. CdR chooses the venue that the DEA provider executes on. CdR lists both the venue and the DEA that it uses, as part of its best execution disclosure. In turn, the DEA provider classifies these trades as directed orders, as the venue chosen is specified by its client (which in this case is CdR). Therefore CdR will disclose the names of its main venues via the DEA, as well as whether there are any close links or specific arrangements with those execution venues.

CdR primary activities involve investing in derivatives. This best execution disclosure covers only the classes of financial instruments that were traded by CdR during the period, as listed below (as per the ‘RTS 28 Annex I – Lists the Classes of financial instruments’). Note that any trades in spot FX are financial instruments outside the scope of MiFID II and therefore not included in this disclosure.

Document Links

• CdR quantitative disclosure of its top five brokers and execution venues is available here.
• CdR Quality of Execution Summary is available here.