Third Platform Services Limited (“TPS” or the “Firm”) offers an automated dealing and settlement service (the “Service”) whereby client orders are executed almost exclusively on a Straight-through-processing (“STP”) basis via the Retail Service Provider (“RSP”) facility operated by Fidessa. The RSP facility is an electronic order routing system on which 28 market making firms display prices and quantities continuously at which they are willing to deal in particular securities. TPS has entered into trade execution agreements with 15 of these market makers (“the Selected Market Makers” or “Execution Venues”).
The Service is provided exclusively to Professional Clients (“Customers”) who are themselves FCA regulated wealth managers acting on behalf of underlying Retail Clients.
TPS’ Customers enter client orders into the Firm’s’ electronic dealing interface which routes such orders directly to the RSP without further manual intervention. The RSP platform automatically matches trade instructions with the best price displayed by the Selected Market Makers for the size of the order concerned . As such, although TPS has defined the constituents of the Selected Market Makers, it does not select the specific market maker, i.e. Execution Venue on which its customers’ orders are executed.
In designing the Service, TPS gave due consideration to the various execution factors – price, costs, speed, likelihood of execution, settlement, trade size, nature of instruments traded and the nature of the Firm’s customer base. TPS considers that its arrangements in this respect are sufficient to obtain the best possible results for its customers taking into account these execution factors.
As noted above, the automated manner in which customers’ orders are executed, means that price is the primary execution factor taken into account in the selection of Execution Venue. TPS monitors the quality of trade execution provided by the Selected Market Makers using the LiquidMetrix Best Execution evaluation tool.
The population of securities for which TPS executes transactions on behalf of its customers is comprised predominantly of highly liquid securities and the prices quoted via the RSP are for retail size orders. These two factors have the effect of reducing the relative importance the Firm needs to give to speed and likelihood of execution as execution factors. Settlement of orders is effected automatically through CREST and, therefore, any delays in settlement will be quickly identified. As such, TPS maintains continuous oversight of the settlement performance of the various Execution Venues it uses and in the event of deteriorating performance, consideration would be given to removing the market maker concerned from the list of Selected Market Makers. No significant issues with respect to settlement performance were noted during the twelve month period ended 31st December 2019 (the “Reporting Period”).
Should customers wish to execute orders that cannot be effected via the RSP, then TPS offers a telephone dealing service which entails the Firm obtaining competing quotes from its brokers. To date, the volume of such trading undertaken by TPS has been minimal and significantly less than one trade per day on average in aggregate across all asset classes.
The Firm does not have any close links, conflicts of interest or common ownership with any of the Execution Venues used to execute its customers’ orders and it does not have any specific arrangements with such Execution Venues regarding payments made or received, discounts, rebates or non-monetary benefits received. There were no changes in the Execution Venues used by the Firm during the Reporting Period.