Technological development, increasing complexity of both products and services, and the financial crisis, led to the decision by the EU to improve the functioning of the financial markets and to strengthen investor protection through the introduction of MiFID II.

MiFID II came into effect on 3 January 2018 and governs both the manner in which firms offer services within the EU as well as determining the rules, systems and controls surrounding the operation of trading venues.

Outlined below is a short overview of Liberum’s current approach to MiFID II as well as the relevant contact details should you have any further enquiries.

Best Execution

In relation to MiFID II’s best execution requirement, Liberum makes the relevant RTS disclosures on its website. RTS disclosures can be found here.

Our Execution Policy can be found here.

For further information regarding our approach to best execution please email dominic.lowres@liberum.com

Trade Reporting and Transaction Reporting

Where possible Liberum reports all trading on venue.

Liberum transaction reports at the client order level using the DEAL capacity.

For further information regarding our approach to trade and transaction reporting please email mike.curnock@liberum.com

Arrangements for the payment for research

MiFID II’s unbundled research requirement has inspired two primary models across the small and mid-cap broking market: the first being a corporate sponsored research approach and the second being a choice between, or a combination of, payment through an institutional client’s own P&L or by way of a Research Payment Account (RPA).

We have taken the view that our research, being highly regarded and valued across our client-base, could potentially be undermined if the corporate sponsored route was implemented. Accordingly, we have chosen to charge our institutional clients for our research. If you would like to receive our research, please contact the MiFID II team at mifid@liberum.com for further information regarding our research offering, costs and what new documentation will be required.

Liberum is not an RPA administrator, but will be able to support collection via transactional and accounting methods.

Legal & Regulatory Arrangements

If you require a copy of our Terms of Business please email compliance@liberum.com

A summary of our Conflicts of Interest policy can be found here.

A copy of our Complaints Procedure can be found here.

Systematic Internaliser?

Liberum is not a systematic internaliser.

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Our offices

London

Ropemaker Place, Level 12 25 Ropemaker Street London EC2Y 9LY

New York

20th Floor 575 Fifth Avenue New York NY 10017