MiFID II FAQs
The updated Markets in Financial Instruments Directive (MiFID II) comes into effect on 3 January 2018. For most EU investment firms, this will mean a number of changes to their business across a variety of areas. Autonomous is committed to helping its clients meet the challenge of MiFID II compliance, and to continuing its business relationships seamlessly into 2018. Below are a number of frequently asked questions that we hope will be helpful. Please also feel free to get in touch with us directly with any MiFID II questions that you might have.
How much do your research services cost?
Since inception, Autonomous has had a clear and transparent pricing model for research services. Our research prices will not change as a result of MiFID II. A full pricing matrix is publicly available on our website (click here).
Will Autonomous be an RPA Administrator?
No, however we will support clients who wish to use RPA Administrators by providing trading services and the movement of Research commission from funds to the RPA on the back of trading. This service will be provided by our UK and US trading desks.
Will any of Autonomous’ products be classified as a Minor Non-Monetary Benefit?
Autonomous will consider various products to be Minor Non-Monetary Benefits, for example:
(a) Short form Sales Trading commentary, updates and trade ideas;
(b) Research product trials (“Tasters”);
(c) Corporate Access;
(d) Short form recaps of news events and published research (with no change of opinion); and
(e) Modest courtesies and refreshments offered in connection with Network Access.
What controls do you have in place to cease sending research to MiFID firms who have formally instructed you to do so?
Autonomous has a centralised process for editing and reviewing our clients’ profiles which directs the dissemination of research and access to our portal. Specific email addresses can be removed from our distribution systems upon client request.
Legal Entities for Trading
In the UK
Autonomous Research LLP
FCA FRN: 500498
LSE Member Mnemonic: ARLP
LSE Member ID: AUAUGB21
In the US
Autonomous Research US LP (not a MiFID investment firm)
The following Trading FAQs apply to Autonomous Research LLP in the UK:
How much does execution with Autonomous Research LLP cost?
Our trading commissions and associated costs are shared with clients prior to trading.
Will Autonomous Research LLP be a MiFID Investment firm?
Will Autonomous Research LLP be a Systematic Internaliser (SI)?
No we will not be an SI in any security.
Will Autonomous Research LLP be a Multilateral Trading Facility (MTF) or Organised Trading Facility (OTF)?
What capacity will Autonomous Research LLP trade in on behalf of clients?
For the majority of trading scenarios, Autonomous will trade as AOTC for equity trades, DEAL for fixed income trades.
Will clients of Autonomous Research LLP have an obligation to make trade reports?
Autonomous Research executes the majority of client orders on venue or via Systematic Internalisers. In these situations, our client will have no trade reporting obligations. A small minority of orders are not traded in this way, but are crossed with other client orders. When crossing we will try by default to bring trades on exchange under the rules of the London Stock Exchange (as an LSE member firm), which means that the client will still have no obligation to trade report. For crosses in any instruments that are not eligible to be brought on exchange, the trade reporting obligation would remain with the client if they are a MiFID investment firm and they are the seller in the transaction. To cover this situation, clients can either opt out from Autonomous executing orders in this way, or can instruct Autonomous to make the necessary trade reports on their behalf via assisted trade reporting.
Will Autonomous Research LLP offer assisted trade reporting?
Autonomous will be able to offer assisted trade reporting to clients. Autonomous currently supports TradEcho and BATS for assisted trade reporting. Other APAs will be added based on client requests.
How do you propose to facilitate the near real time exchange of MiFID data points in a voice trading environment?
For clients that currently trade with us via voice, we would recommend reviewing the possibility of migrating to an electronic connection. Or if that is not possible, to opt out from trades that would require a real time exchange of MiFID data points.
Will Autonomous Research LLP utilise the new MIFID II guidelines as proposed by the FIX Trading Community?
Yes, and as there is much flexibility offered we will in addition normalize the flow coming from our brokers to our clients.
What additional transaction reporting data will clients need to provide to Autonomous Research LLP?
Legal Entity Identifier (LEI), and short selling flag data.
What transaction reporting data will Autonomous Research LLP provide to clients?
For clients that are sending us orders via FIX, will provide all relevant data for transaction reporting via FIX. Clients not connected via FIX will receive a .csv file on T+1 containing all transaction reportable information.
Will Autonomous Research LLP offer delegated transaction reporting or ‘Transmission Under Article 4’?
Autonomous Research LLP does not currently plan to offer this service. Market consensus appears to be that this will be prohibitively complex and raises many issues around data protection and personal data. However, if you would like to discuss this further, please contact us at the address below.
Will you be updating your Order Execution Policy?
Yes. This will be made available in Q4 2017 alongside the updated Terms of Business.
What best execution disclosures will you make?
We will disclose our top 5 executing venues in Q1 2018. This information will be available on our website.
Will you be providing Direct Electronic Access (DEA) to us?
No, Autonomous Research LLP will not be a DEA provider.
Will you be updating your Terms of Business?
Yes. Updated Terms of Business will be sent to the majority of clients in Q4 2017.
Who can I contact for more information?
Please contact us at firstname.lastname@example.org