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Version date: 10 October 2016 - onwards

5.21 Investment Firm introducing without interposing

5.21.1 Investment Firm matching two orders from clients without interposing itself

Example 53

Investment Firm X wants to sell a given instrument on own account.

Investment Firm Y wants to buy that same instrument on own account.

Investment Firm Z brings together Investment Firms X and Y but is not a party to the transaction.

Investment Firms X and Y agree between themselves on the details of the transaction.

Investment Firm Z does not have any reporting obligation, instead Firms X and Y should report.

Investment Firm X knows at the point of execution that Y is its counterparty.

Investment Firm Y knows at the point of execution that X is its counterparty.

How should Investment Firms X and Y report?

5.21.2 Investment Firm introducing its client to another Investment Firm without interposing itself

Example 54

Client A wants to buy a given instrument. His broker, Firm X, does not deal in such instruments and introduces Client A to Investment Firm Y.

Investment Firm Y purchases the financ

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