RTS28-2022

Introduction

As required by the Markets in Financial Instruments Directive (“MIFID II”), investment firms such as CiliaFormosa Financial Advisors Ltd (“CFFA”) are required to summarise and make public the top five execution venues used in relation to the volume of trades placed across a range of financial instruments for all executed client orders on an annual basis.

 

This report provides the information required above in respect of trades executed in calendar year 2022.

Retail Clients

Class of Instrument Debt Securities
Notification if < 1 average trade per business day in the previous year Yes
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
Malta Stock Exchange 5299009CKES2S5E3YG94 99.11% 97.78% 97.71% 100% 0%
Bank of Valletta plc 529900RWC8ZYB066JF16 0.89% 2.22% 2.30% 0% 0%

Class of Instrument Equities
Notification if < 1 average trade per business day in the previous year Yes
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
MeDirect 529900SYUCFQHI3JZQ05 58.91% 56.92% 57.60% 40% 0%
Bank of Valletta plc 529900RWC8ZYB066JF16 37.97% 33.85% 32.80% 60% 0%
Malta Stock Exchange 5299009CKES2S5E3YG94 3.13% 9.23% 10% 0% 0%
Class of Instrument Exchange Traded Securities
Notification if < 1 average trade per business day in the previous year Yes
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
Bank of Valletta plc 529900RWC8ZYB066JF16 100% 100% 100% 0% 0%

Professional Clients: Not Applicable

Class of Instrument Equities
Notification if < 1 average trade per business day in the previous year N/A
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
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Class of Instrument Debt Securities
Notification if < 1 average trade per business day in the previous year N/A
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
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A
Class of Instrument Exchange Traded Securities
Notification if < 1 average trade per business day in the previous year N/A
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
Name and Venue Identifier (MIC or LEI) N/A N/A N/A N/A N/A

Commentary as required by Commission Delegated Regulated (EU) 2017/576 (RTS 28)

The below commentary is applicable to all classes of financial instruments, unless otherwise specified:

 

a) The relative importance the firm 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:

When executing orders on behalf of clients, and as outlined in the Company’s Best Execution policy, the Company takes all sufficient steps to obtain the best possible results for the Clients.

Best execution factors are to be viewed holistically, considering both quantitative and qualitative

factors on a case-by-case basis. The relative importance of the execution factors is determined by

using industry practice and experience, expertise and the best judgement in light of all the available market information and resources. The prevalent aim is the attainment of prompt, fair and expeditious execution of trades. The following factors are considered:

  • Price;
  • Costs;
  • Speed;
  • Likelihood of execution and settlement;
  • Size;
  • Nature of transaction; and

Any other consideration relevant to the execution of the order.

 

b) Description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.

CiliaFormosa Financial Advisors Ltd does not have any close links, conflicts of interests or common ownerships with respect to any execution venues used to execute client orders.

 

c) Description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

CiliaFormosa Financial Advisors has no specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits.

 

d) 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.

The Best Execution policy allows the Company to act in the best interest of the client, and to obtain the best possible execution of the order.

No changes were made to the Best Execution Policy.

 

e) 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.

Where the Company executes an order on behalf of a Retail Client, the best possible result shall be determined in terms of the total consideration, representing the likelihood, the speed of execution and the price of the Financial Instrument, as well as

the costs relating to execution, which shall include expenses incurred by the Client, directly

related to the execution of the order, including Execution venue fees, clearing and settlement fees

and any other fees paid to third parties involved.

Apart from all the above, the Company takes into consideration the size of the transaction when dealing with orders for Professional clients.

 

f) 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.

No other criteria was given precedence over price, costs, speed and likelihood of execution, when executing retail client orders.

 

g) Explanation of how the investment firm has used any data or tools relating to the quality of execution.

The company uses In-house research and information/data and it also makes use of publicly available data sources as necessary.

 

h) Explanation of how the investment firm has used output of a consolidated tape provider.

Not applicable