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. Have you updated your Terms of Business?
Yes, These were updated in Q4 2017 for MiFID II, along with the accompanying policies that are required to 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 in respect of Numis’ execution of client orders.
For reference Numis’ LEI is 213800P3F4RT97WDSX47
Annual reporting under RTS 28 has been a requirement with respect to the execution of client orders for each calendar year commencing 2017. The introduction of MiFID II in January 2018 required additional granularity of information to be captured by MiFID Investment Firms when executing client orders. ESMA provided some dispensation regarding reporting 2017 data in recognition that it preceded the MiFID II Requirements. The reports for both 2017 and 2018 are made available below.
Comparing 2018 and 2017 Reports
1. Client Categorisation
Numis considers it has a duty of Best Execution to both Professional and Retail clients. The top 5 execution venues are recorded separately for each client category. This is consistent for both years.
2. Class of Instrument
Numis has separately recorded the top 5 execution venues for the following instrument classes; Equities, Debt, Exchange Traded Funds (ETFs) and ‘Other’ Instruments. The classes of instrument have remained consistent for both years.
3. Liquidity Bands
Reporting by three distinct liquidity bands for equities is new for 2018. Thus for both Professional and Retail clients we have recorded 2018 data separately as follows:
Equities Liquidity Band (ELB) 1,2: 0 to 79 trades per day
Equities Liquidity Band (ELB) 3,4: 80 to 1999 trades per day
Equities Liquidity Band (ELB) 5,6: 2000+ trades per day
4. Orders which are Passive, Aggressive or Directed
MiFIR Article 2 definitions are as follows:
‘Passive Order’ means an order entered into the order book that provided liquidity
‘Aggressive Order’ means an order entered into the order book that took liquidity
‘Directed Order’ means an order where a specific execution venue was specified by the client prior to the execution of the order.
Entries in these fields are new to the 2018 reports.
Numis does not offer a service to clients whereby orders can be entered directly onto the order book. For our Regulatory Reports therefore, in accordance with the above definitions, the passive and aggressive fields in each case would record a zero result. Numis has however analysed its execution data to consider, on the basis of the execution price relative to the market price, whether liquidity can be ‘deemed’ to be provided or taken (or potentially neither, which is why the combination of passive and aggressive trades seldom add up to 100%).
It will be apparent that the ‘Directed’ order fields consistently show a zero result. This is not in error and is not particularly surprising. Typically Numis’ clients require Numis to consider competing sources of price competitive liquidity.
Categories where there is less than 1 trade per business day
ESMA accepts that in categories where an investment firm only executes a small number of client orders, information on the top five execution venues would not be very meaningful and potentially misleading. For this reason, where we disclose in the report that Numis has executed less than one order a day no further information is provided.
Regulatory and Supplementary Reports
In addition to our Regulatory Reports, we have considered it would be helpful to describe the top five execution venues where we sourced liquidity when executing client orders. This is set out in our Supplementary Reports using the same reporting format as for the Regulatory Reports.
Reporting in accordance with RTS 28 Article 3.3
Numis is required to publish for each class of financial instrument, a summary of the analysis and conclusions drawn from detailed monitoring of the quality of execution obtained on all execution venues used for client orders in the previous year.
RTS 28 Reports for 2017
RTS 28 Reports for 2018
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