RTS28 2017
Atlantic House Fund Management LLPTop 5 Venues Execution Report 2017
Introduction
This document has been issued by Atlantic House Fund Management LLP (AHFM) who is authorised and regulated by the Financial Conduct Authority (‘FCA’) as a MiFID Investment Firm; the main regulated activity it performs is portfolio management for clients that meet the FCA handbook definition of ‘professional client’ and ‘retail client’. AHFM has published this document in line with the requirements of MiFID II and supplementing Regulatory Technical Standards (RTS). The legislation requires portfolio managers to summarise and disclose annually the top five execution venues in terms of trading volumes where they executed decisions to deal in the preceding year and associated information on the quality of execution for each class of financial instrument. AHFM do not have a centralised dealing team however trade execution must follow the AHFM Execution Policy, the dealing element of the investment management team’s responsibilities is overseen as part of the firm’s compliance monitoring program. Transactions are concluded with external counterparties in relation to the discretionary investment decisions made by AHFM’s portfolio management teams. During 2017, AHFM undertook dealing in the following financial instruments for clients.
Debt Instruments: Bonds
Interest Rate Derivatives: Swaps, forwards, and other interest rates derivatives
Equity Derivatives: Swaps and other equity derivatives
Securitised Derivatives: Other securitised derivatives
Glossary & Abbreviation of Terms
| Abbreviation/Term | Definition |
| Aggressive Orders | Aggressive order means an order entered into the order book that took liquidity. |
| AHFM | Atlantic House Fund Management LLP |
| Directed Orders | Directed order means an order where a specific execution venue was specified by the client prior to the execution of the order |
| FCA | Financial Conduct Authority |
| MiFID | Markets in Financial Instruments Directive |
| OTC | Over the counter (OTC) is a security traded outside of a formal exchange via an agreement between two parties. |
| Passive Orders | Passive order means an order entered into the order book that provided liquidity. |
| Total Return Swap (TRS) | A total return swap is a swap agreement in which one party makes payments based on a set rate, either fixed or variable, while the other party makes payments based on the return of an |
| Venue | A venue is where a client order is executed. For this report we show the legal name of the venue that the order was passed to. |
Quantitative report and Qualitative commentary for each asset class
| Class of instrument | Debt Instruments: Bonds | ||||
| Notification if < 1 average trade per business day in the previous year | Y | ||||
| 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 |
| J P Morgan | 100% | 100% | – | – | – |
| Qualitative Commentary | The primary trading factors considered for this asset class when selecting the venue were price and likelihood of execution and size. J P Morgan were consistently the counterparty who were able to provide good execution taking in to account the requirement to link the transactions to Interest Rate Swaps. The volumes in 2017 were in the single digits. |
| Class of instrument | Interest Rate Derivatives: Swaps, forwards, and other interest rates derivatives | ||||
| Notification if < 1 average trade per business day in the previous year | Y | ||||
| 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 |
| J P Morgan | 100% | 100% | – | – | – |
| Qualitative Commentary | All trades were executed with Citigroup, the interest derivatives were linked to the Bonds transaction detailed above. We have internal models to ensure best execution is provided by the counterparty. |
| Class of instrument | Equity Derivatives: Swaps and other equity derivatives | ||||
| Notification if < 1 average trade per business day in the previous year | N | ||||
| 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 |
| J P Morgan | 58.73% | 54.14% | – | – | – |
| Credit Suisse | 19.87% | 20.70% | – | – | – |
| Natixis | 18.18% | 15.23% | – | – | – |
| UBS | 2.07% | 7.28% | – | – | – |
| Société Générale | 1.16% | 2.65% | – | – | – |
| Qualitative Commentary | AHFM trades some equity index/basket product through OTC swaps. These are executed with a counterparty under ISDA documentation, which needs to be in place for all funds/accounts trading the swap. AHFM have a rich list of top tier investment banks to choose from, each Swap is transaction goes through an RFQ process. We have internal pricing models to ensure pricing received is of good standing. |
| Class of instrument | Securitised Derivatives: Other securitised derivatives | ||||
| Notification if < 1 average trade per business day in the previous year | Y | ||||
| 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 |
| HSBC | 30.89% | 22.99% | – | – | – |
| Natixis | 22.37% | 49.43% | – | – | – |
| Credit Suisse | 20.10% | 12.64% | – | – | – |
| Investec | 15.49% | 4.60% | – | – | – |
| J P Morgan | 7.00% | 6.90% | – | – | – |
| Qualitative Commentary | Across 2017 AHFM traded structured investments with a selection of counterparties. For these products a competitive RFQ process is held, we are able to price each product using internal models to ensure pricing receive is competitive. |
Qualitative Report
In accordance with Article 3(3) of RTS 28, AHFM hereby publishes a summary of the analysis and conclusions the firm has drawn from detailed monitoring of the quality of execution obtained during 2017. This qualitative report attempts to provide a more transparent picture of the firm’s order execution policy in practice, execution strategies and tools used to assess the strategies’ quality. The qualitative commentary has been inserted at the bottom of each asset class above.