RTS 28 Annual Best Execution Disclosure For the year ended 31 December 2019
Sandbar Asset Management LLP (“Sandbar” or the “Firm”) is required to provide an annual disclosure regarding execution venues and brokers that it uses for each asset class as well as information regarding the quality of execution received. This disclosure covers the following classes of financial instruments that were traded during the period: (1) equities – shares and depositary receipts; and (2) contracts for difference.
The Firm invests on behalf of its clients, primarily in equities and as such, the instruments traded in the period were cash equities and equity swaps / CFDs. The Firm’s strategy is to trade in highly liquid, all listed stocks primarily in the U.S. and developed European markets although it may choose to trade certain Asian stocks.
The Firm continually assesses the list of counterparties it uses with the ultimate goal of obtaining the best result for our clients. Although the firm has pre-negotiated commissions with its execution brokers and maintains an internal transaction cost analysis, the commission rates are not always the most important factor when choosing an executing broker. The Firm does not act for retail clients and, accordingly, does not always consider the total consideration to be the most important factor in achieving the best possible result for its clients in respect of a particular trade. As a significant proportion of orders are algorithmic in nature (such as VWAP), order size and likelihood of execution in the manner intended can be more important. All executions are monitored by the trader with an informal review performed by the portfolio manager.
There are no close links, common ownership that would give rise to any conflicts of interests with any of the execution venues or brokers used. Additionally, none of our clients have discretion over the counterparties used to trade.
Special Arrangements with Execution Brokers and Venues
The Firm does not receive any discount or rebates in relation to execution services. Although we may on occasion receive short term market colour from our execution providers, it does not influence the choice of executing broker.
Changes to Execution Brokers and Venues
Counterparties are continually assessed, and the Firm may at its discretion remove or add from the authorized broker list depending on results of its execution and broker reviews as well as trading requirements.
Monitoring Quality of Execution
Best execution and conflicts of interest that may arise in the context of appointment of execution brokers are monitored in accordance with the Firm’s Order Execution and Conflicts of Interest policies. Further information on these policies is available on request.
Top 5 Brokers and Venues