Best Execution - meeting FCA Expectations - 21/09/2017
The Training Environment For Financial Services

Best Execution - meeting FCA Expectations

21 Sep 2017, London

9:00am to 12:15pm

Outline & Objectives

The FCA rules, guidance and ‘standards’ for Best Execution have been in place since the introduction of MiFID seven years ago. Despite this, the FCA’s thematic review of Best Execution found only a very small proportion of the firms visited actually understood and complied with the totality of the Best Execution requirements, with the majority lacking an understanding of the full scope of the requirements, how to define and monitor Best Execution and what constitutes appropriate governance More worryingly, the regulator has pointed to a disconnect between Front Office and Compliance approaches to Best Execution, with Compliance often being kept away from Best Execution issues, due to a perceived lack of skills and understanding. Some firms have even tried to circumvent the prohibition on payment for order flow by redrafting legal documents to achieve the same effect.

Making use of CASE STUDIES and SYNDICATE EXERCISES, this practical course will help Compliance and Front Office professionals keep up to date with the evolving rules, guidance and standards in this critical area of business and regulatory risk.

Specifically, attending will help you:

  • Review the impact of regulatory developments and priorities flowing from TR 14/13
  • Update and refresh your knowledge of the regulatory requirements and the changing regulatory landscape
  • Review the appropriateness of your best execution arrangements
  • Understand the importance of an effective monitoring structure
  • Review the appropriateness of your best execution governance
  • Understand how meeting the requirements will affect your business and client interactions
  • Consider how you can get Compliance and the Front Office working effectively together

Training Approach

This workshop uses a combination of trainer input, knowledge sharing with interactive syndicate work and case studies. Group size is kept to a maximum of 16 to facilitate sharing of experience amongst the delegates.

Course Presenter

Gary Pitts has 20 years of compliance experience, including spells with the Personal Investment Authority, Henderson Global Investors, Brevan Howard Asset Management, Religare Capital Markets and as a Managing Partner of Solo Capital Partners. He now runs his own regulatory and governance consultancy, Tetractys Partners LLP. He has extensive asset management, hedge fund and investment banking experience in addition to a broad and deep understanding of corporate governance. Gary is a regular conference speaker and author of technical articles on compliance-related topics. He sits on the regulatory advisory group of the Journal of Securities Operations and Custody. Gary holds Masters degrees from Oxford and London Universities and an MBA from the Open University Business School, is a former director of Cayman and Luxembourg domiciled hedge funds, as well as regulated companies in the UK and South Africa. Gary has been an FSA/FCA registered person in Controlled Functions 10 and/or 11 since 2001. He brings a combination of compliance and commercial experience, in terms of both practical implementation and Board level oversight, to the training he delivers.

Course Programme

Session Aim Content
The scope of the rules To consider the scope of the FCA best execution requirements and why firms fail to identify the full reach of the application of the Rules
  • What is the full scope of the requirements?
  • What this means for firms
  • An exploration of why firms get it wrong
Defining Best Execution for your firm To know what constitutes “Best Execution” in the context of your firm’s clients and activities
  • Definition of “Best Execution”
  • Execution factors and how to weight them (syndicate exercise)
  • Evidencing your work
  • Interaction of Compliance and Front Office
Evidencing venue selection To be able to review trading venues and systems for alignment with the firm’s identified best execution factors
  • Factors to consider when reviewing brokers
  • Factors to consider when reviewing trading venues and trading algorithms?
  • Syndicate exercise
Constructing a value-added monitoring programme To use a framework to build an effective monitoring programme that produces value-added management information
  • First and Second line monitoring
  • The roles of Front Office and Compliance
  • The use of automated monitoring
  • Syndicate exercise / group discussion
Payment for Order Flow To understand the definition of payment for order flow arrangements and why these are prohibited
  • What is payment for order flow and why is it prohibited?
  • Learning to identify disguised payment for order flow arrangement
Best Execution Governance To identify the governance requirements for Best Execution, with an emphasis on meeting the FCA SYSC requirements
  • The importance of proper governance
  • Regulatory benchmarks for governance?
  • Ownership of the governance process
  • Management Information – sorting the wheat from the chaff (syndicate exercise)
Compliance oversight and internal audit To consider the respective roles of Compliance and Internal Audit and the skill sets required to deliver effective advice and monitoring
  • Roles of Compliance and Internal audit?
  • How do we avoid overlap?
  • What specific skill sets do we need for our staff and how do we acquire them?
The future – what does MiFID 2 hold for Best Execution? To examine the proposed changes in MiFID 2 relating to best execution and the structure of the market
  • What are the proposed changes?
  • How will they build on the current requirements?
  • What is the timetable?
  • Future-proofing – what we need to think about?

This course can be delivered in-house at a time and location to suit your business and tailored to suit your people and organisation. We can also create bespoke training when something very specific is needed.Please contact us to discuss your requirements in more detail and at no obligation.

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