(pursuant to Annex II, Table 1 Delegated Regulation (EU) 2017/576)
Bad Homburg, in November 2019
A new feature of MiFID II is the obligation of the institute, to annually publish the five execution venues for each category of financial instrument on its website, which are most significant in terms of trading volumes through which it executed client orders in the previous year, and to summarise information on the quality of execution achieved (Section 82, Sub-section 9 Securities Trading Act). As the institute selected other investment firms for transacting client business, the five most important custodian depots (settlement banks) are to be named in this case and information on these firms regarding the quality of execution achieved summarised. Further information on this publication can be found in the Delegated Regulation (EU) 2017/576. According to ESMA, the reports are to be made available on the website for at least two years.
Note: The data refers to the business year (1 January to 31 December) of the institute.
As a matter of principle, HQ Trust GmbH does not pass investment decisions directly to trading centres, rather to the client’s respective depot bank, which executes the instructions. Though careful selection and monitoring of the banks, HQ Trust GmbH works towards the best possible implementation of the trading decisions.
In the context of wealth management, we are obliged by Article 65 of the Delegated Regulation 2017/565 to act in the best interests of our clients and take all adequate measures to achieve the best possible results for our clients. In order to comply with these stipulations, we select the executing institutions so that their execution principles ensure the best possible order implementation, in particular that the best possible result is achieved for our clients.
Our selection criteria are:
These criteria are to be weighted taking customer order, the financial instrument and the place of execution into consideration.
During the course of the business relationship, we monitor whether the executing institutions carry out the orders in compliance with their executions principles. Once a year, we verify the execution policies of the executing institutions for compliance with the above criteria and, where appropriate, would amend the selection.
There are no close connections, conflicts of interest or joint ownerships relating to banks or execution venues.
No special agreements apply with banks or execution venues with regard to payments made or received or discounts, trade allowances or other non-monetary considerations received.
No changes of the selected banks were undertaken in the wealth management portfolio.
HQ Trust does not differentiate in the execution between private clients and professional clients.
The best possible results are based on the complete price, made up of the price for the financial instrument and all other costs associated with the execution of the order (including fees and charges levied by the place of execution, costs for clearing and processing and all other charges).
During the course of the business relationship we monitor whether the executing institutions carry out the orders in compliance with their execution policies. This ensues on the basis of the confirmation of execution or bought/sold notes which we receive from the executing institutions.
No consolidated tape provider is used.