Technological development, increasing complexity of both products and services, and the financial crisis, has led to the decision to reform and replace the existing EU regulatory framework with MiFID II. MiFID II comes into effect from 3 January 2018 and will lead to fundamental and wide-ranging reforms which will have a significant impact on financial institutions operating in the EU. It will govern both the manner in which firms offer services within the EU as well as determining the rules, systems and controls surrounding the operation of trading venues, with the aim of making financial markets more efficient and transparent, and to strengthen the protection of investors.
We have received a number of queries from clients regarding MiFID II and outlined below is a short overview of Liberum’s current approach to the new regulation as well as the contact details should you have any further enquiries.
Where possible Liberum intends to report all trading on venue.
Liberum will transaction report at the client order level using the DEAL capacity.
For further information regarding our approach to trade and transaction reporting please email firstname.lastname@example.org
In relation to MiFID II’s best execution requirement, Liberum will make the relevant RTS disclosures on its website.
We will be updating our execution policy and this will be made available during the course of Q4 2017.
For further information regarding our approach to best execution please email email@example.com
We will be updating our Terms of Business and this will be provided to clients during the course of Q4 2017.
Several of our policies may also require updating and we expect these documents to be available during the course of Q4 2017.
For further information in relation to our legal arrangements please email firstname.lastname@example.org
MiFID II’s unbundled research requirement has inspired two primary models across the small and mid-cap broking market: the first being a corporate sponsored research approach and the second being a choice between, or a combination of, payment through an institutional client’s own P&L or by way of a Research Payment Account (RPA). While some of our competitors will be adopting the corporate sponsored research model (i.e. seeking payment from their corporate clients), we have taken the view that our research, being highly regarded and valued across our client-base, could potentially be undermined if the corporate sponsored route was implemented. Accordingly, we have chosen to charge our institutional clients for our research. If you would like to receive our research post 3 January 2018, please contact the MiFID II team at email@example.com for further information regarding our research offering, costs and what new documentation will be required.
Liberum does not intend to become an RPA administrator, but will be able to support collection via transactional and accounting methods.
Liberum does not intend to become a systematic internaliser.
Legal Entity: Liberum Capital Limited
FCA FRN: 465050
NEW YORK OFFICE
Legal Entity: Liberum Capital Inc
FINRA: CRD# 148135
SEC: SEC# 8-67976