MiFID II Execution Venue Disclosure – 2020

Capricorn Private Investments (“CPI”, “the firm”) is a registered trading name of Capricorn Capital Partners UK Limited, a company authorised and regulated by the FCA (FRN 748414).

The firm is required, on an annual basis, to publish qualitative and quantitative information in relation to its client orders executed on trading venues, systematic internalisers, market makers or other liquidity providers or such entities.

CPI only executes client orders with its approved brokers (“brokers” or “execution venue”). The firm is required to publish the top five execution venues in terms of trading volume and number of trades per class of financial instruments on an annual basis.

Set out below is a summary of the analysis and conclusions drawn from its monitoring of the quality of execution obtained from its brokers. This report has been prepared by CPI for the period ending 31 December 2020 (the “Reporting Period”).

 

Classes of Financial Instruments

There are thirteen classes of financial instruments, listed below, which the firm is technically required to report on:

  • Equities
  • Debt Instruments
  • Interest Rate Derivatives
  • Credit Derivatives
  • Currency Derivatives
  • Structured Finance Instruments
  • Equity Derivatives
  • Securitised Derivatives
  • Commodities Derivatives and Emission Allowance Derivatives
  • Contracts for Difference
  • Exchange Traded Products
  • Emission Allowances
  • Other Instruments

It should be noted that during the Reporting Period CPI did not trade in all of the above financial instruments, resulting in only 3 reports, as follows:

  • Equities
  • Exchange Traded Products

 

Qualitative Analysis of Execution Obtained

Qualitative information below is provided on a consolidated basis for all classes of financial instruments since there are no differences in execution methods and strategies depending on the nature of the instrument.

 

Execution Factors

Under RTS 28, the firm must provide an explanation of the relative importance it gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution.

In accordance with its Best Execution Policy, the firm considers a number of execution factors when assessing the quality of execution it receives from its brokers.

For all financial instruments set out below, the firm places the highest importance on price and costs associated with execution referred to as total consideration when determining which execution venue to use. In addition to price and cost, CPI considers other factors (when deemed to deliver the best possible result):

·         Likelihood of execution and settlement

·         Speed of execution

·         Size and nature of order

·         Market impact

·         Any other consideration relevant to the execution of an order

 

Close Links and Conflicts

Under RTS 28, the firm must provide a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.
The firm has no close links or ownership stakes in any of the execution venues listed in this document. No conflicts of interest have been identified with respect to any execution venue it has used to execute client orders.

 

Inducements and Specific Arrangements

Under RTS 28, the firm must provide a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.
The firm has no specific arrangements with any execution venue it has used to execute client orders regarding discounts or payments made or received. The firm does not receive any third-party payments, including rebates or non-monetary benefits from any current execution venue.

 

Change in the List of Execution Venues

Under RTS 28, the firm must provide an explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred.
During this Reporting Period, there has been no change to the list of execution venues listed in the execution policy.

 

Client Categories

Under RTS 28, the firm must provide an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements.
The firm only deals with Professional Clients (as defined in the Markets in Financial Instruments Directive (Directive 2014/65/EU)). There is no difference in the order execution received by CPI clients.

 

Retail Client Orders

Under RTS 28, the firm must provide an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client.
N/A – the firm only deals with Professional Clients and has no Retail Clients.

 

RTS 27

Under RTS 28, the firm must provide an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under RTS 27.
CPI may utilise the data published by its execution venues under RTS 27 to the extent that it is available in a consistent and coherent format. Such data could be used to meaningfully contribute to its assessment of the quality of execution received on behalf of the firm’s clients.

 

 Consolidated Tape Provider

Under RTS 28, the firm must provide, where applicable, an explanation of how the firm has used output of a consolidated tape provider which will allow for the development of enhanced measures of execution quality or any other algorithms used to optimise and assess execution performances (if applicable)
N/A – the firm has not used a consolidated tape provider.

 

Quantitative Information of Top Execution Venues

For each reportable class of financial instrument, the following information will be provided:

  • The execution venue name and LEI
  • Information on the total volume
  • The number of trades as a percentage of all client orders executed on that execution venue
  • Confirmation if the firm has executed an average of less than one trade per business day in the previous calendar year in that class of financial instrument

 

Equity – All  

Class of Instrument Equity – All
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

Deutsche Bank (Suisse) SA

(LEI – 529900BXKPMXQTRE1V05)

100.00% 100.00% 100.0% 0.0% 0.0%

 

Exchange Traded Products – All 

Class of Instrument             Exchange Traded Products – All
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

Deutsche Bank (Suisse) SA

(LEI – 529900BXKPMXQTRE1V05)

88.21% 84.21% 84.21% 0.0% 0.0%

Cidel Bank & Trust Inc.

(LEI – 549300MATQ2L03SLFT65)

11.79% 15.79% 15.79% 0.0% 0.0%