Top 5 Trading Venues
The Markets in Financial Instruments Directive (MIFID II) requires investment firms to summarise and make public, on an annual basis, the top five execution venues used (brokers or counterparties) in relation to the volume of trades placed across a range of financial instruments. Investment firms are required to publish this summary both for trades they have executed themselves, and for trades they have placed with other firms for execution.
| Custodian/Broker | Legal Entity Identifier | Volume |
| Goldman Sachs International | W22LROWP2IHZNBB6K528 | 44.5% |
| Brown Shipley & Co. Limited | 5493003MITCIX89B0R76 | 17.5% |
| Citibank (Switzerland) AG | 4BVL95XIH9NNZF0YN485 | 7.3% |
| Interactive Brokers LLC | 50OBSE5T5521O6SMZR28 | 6.9% |
| Flow Traders B.V. | 549300CLJI9XDH12XV51 | 5.8% |
| Other including:Goldman Sachs & Co. LLC HSBC Private Bank Jane Street Financial Limited Northern Trust Securities LLP Societe Generale Stonehage Fleming Dealing and Treasury Services (Jersey) Limited Susquehanna International Securities Limited | 17.9% |
Annual Report About Monitoring of the Execution Quality of all Used Execution VenuES
| Requirement | Firm assessment |
| An explanation of 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. | For Separately Managed Accounts Omba does not hold Client Money or Custody of the client’s assets. We work with their nominated custodian to place orders and have reviewed their Best Execution Policies where applicable. Orders are placed at a limit price and actively monitored throughout the trading period. Where acting as Investment Manager to the Omba fund range price plays an important part as does liquidity in determining the market and broker. |
| A description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders. | There are no close links, conflicts of interest or common ownerships with respect to any brokers with whom Omba have placed orders. |
| A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received. | There are no payments made or received, discounts, rebates or non-monetary benefits received from brokers. |
| 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. | The addition of Authorised Participants to Tradeweb as an MTF venue for placing orders directly where applicable and in the Omba fund ranges’ best interests from a price perspective. There was also the addition of new client custodians and their associated Dealing desks for placement of orders under our Discretionary mandate. |
| 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 retail clients and therefore order execution does not differ according to client categorisation. |
| 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. | No other criteria were given precedence when providing retail clients with best execution. |
| An explanation of how the investment firm has used any data or tools relating to the quality of execution. | Throughout 2020 Omba routinely monitored the quality of execution obtained from Custodians. Our systems monitor confirmed execution details versus placed orders and we proactively work with custodians to rectify issues relating to limit price, execution date or filled quantity where applicable. |