The activity of a non-executing broker is different to direct electronic access (DEA) as defined under Article 4(1)(41) of MiFID II. Article 2(1)(d) of Commission Delegated Regulation (EU) 2017/580 together with Field 6 provides that this service arises when a member or participant of a Trading Venue (the non- executing broker) routes an order to the Trading Venue on behalf of and in the name of another member or participant of the Trading Venue.
Example 119
Investment Firm X submits an order for execution to Trading Venue M through non-executing broker Investment Firm Y on behalf of Client Z.
