MiFID II FAQs
1. What are Numis' legal names and associated LEIs?
(EMEA clients) NUMIS SECURITIES LIMITED (NSL) 213800P3F4RT97WDSX47
(US clients) NUMIS SECURITIES INC. (NSI) 213800GW3YZJDBPALN37
Above are the legal entities whose LEIs are most commonly requested. The LEIs for other Numis group companies are available on request.
2. Which asset classes does Numis trade?
We are a market maker, trading in a principal capacity, focussed on executing orders from our dealing clients in equity or equity-like instruments.
3. In what trading capacity or capacities (DEAL, AOTC or MTCH) will Numis be acting?
It is our expectation that the trading capacity for all transactions will be “DEAL”.
4. Will Numis be a Systematic Internaliser (“SI”)?
We do not plan to operate as a Systematic Internaliser as defined by MiFID II.
5. Will our clients need to trade report?
There may be limited scenarios where, under applicable law, the trade reporting obligation falls to our client. In most instances this is not the case. This is because when Numis trades with its clients we generally do so under the rules of the London Stock Exchange ("LSE"). This means that we will bring trades "on Exchange" in accordance with the current LSE Rule 3000 (i.e. off-book, on-Exchange trades). The Exchange’s APA will then ensure any trade reporting obligations are met.
We expect that a small minority of transactions with Numis will not be eligible to be brought on Exchange nor form part of a riskless principal chain where one leg is on venue. In such circumstances, if our client is the seller, then an obligation for them to trade report may arise. However, Numis is offering clients the option to elect to receive an assisted trade reporting service (see below), at no charge. This will help our clients meet their trade reporting obligations.
Clients of Numis that are not categorised as a MiFID Investment Firm will not have an obligation under MiFID II to trade report when trading with Numis in instruments captured by MiFID II.
6. Will Numis offer assisted trade reporting?
If, under applicable law, our client has an obligation to trade report a transaction with Numis then, providing our client has entered into an agreement to receive Numis’ assisted trade reporting service, Numis will determine whether our client has a responsibility to trade report and, if so, send the necessary details and instruction to our client’s APA (with whom our client will also have an assisted trade reporting agreement). We currently expect to support requests from our clients for assisted trade reporting to the APAs; TRADEcho or BATS. Other APAs may be added in due course.
Please let us know if you wish to receive our assisted trade reporting service and which APA you have engaged to trade report equity or equity-like transactions.
7. Will Numis offer delegated transaction reporting?
Numis will not be offering a delegated transaction reporting service.
Clients of Numis that are not categorised as a MiFID Investment Firm will not have an obligation under MiFID II to transaction report when trading with Numis in instruments captured by MiFID II.
8. Electronic Orders & Trading via FIX
We will adhere to FIX standards as developed for MiFID II. All relevant mandatory tags will be populated. If you have any bespoke requirements it is important you contact our Client Fix Connectivity team (see MiFID II contacts below).
9. How much will Numis charge for access to Research Facilities?
Our provision of Research Facilities, and access to our Research Facilities, is bespoke for each client. Please contact Vicki Miller for more details (see MiFID II contacts below).
10. How can clients pay for access to Research Facilities?
Clients can pay for Research Facilities out of their own accounts, or through a research payment account.
11. Will you be updating your Terms of Business?
Yes, we expect that these will be updated for MiFID II in Q4 2017, along with any accompanying policies which must be publicly disclosed.
12. Do you have a list of MiFID II contacts at Numis if I have any further questions?
MiFID II Reporting In Accordance With Regulatory Technical Standards (RTS) 28 For Numis Securities Limited (Numis)
In accordance with RTS 28, Numis is required to summarise and make public on an annual basis, the top five execution venues where Numis executed client orders. Our Regulatory Reports providing data for 2017 are found in this section.
The Regulatory Reports provide data on the top five execution venues by trading volume, separated by Client Category (Professional or Retail) and by Class of Instrument (Equities, Debt Instruments, Exchange Traded Funds, Other Instruments).
With respect to the first Regulatory Reports under this Regulation (in respect of calendar year 2017) ESMA recognises that some granularity of information may be unavailable that would be available for subsequent reports under MiFID II which came into force in January 2018. Specifically the limitations in mapping data for the 2017 reports were:
ESMA accepts that where an investment firm only executes a small number of orders, information on the top five execution venues would not be very meaningful. For this reason, where we disclose in the report that Numis has executed less than one order a day no further information is provided.
In addition to these reports, Numis considers it would be helpful to describe how it sourced liquidity in the process of executing client orders. This is set out in Supplementary Reports using the same reporting format as for the Regulatory Reports. The limitation to mapping the aggressive or passive characteristics and whether orders were directed applies equally to the Supplementary Reports.
The individual reports are provided in CSV format.
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