Under MiFID and MIFID II after 3 January 2018, HSBC Bank plc acting through its Global Banking and Markets business is required to take sufficient steps to obtain the best possible result for its clients when executing orders on their behalf.
In order to detail our approach, we include below the 2017 disclosure statement that will prevail up to the 2 of January 2018, and the 2018 disclosure statement that complies with MiFID II and will apply from the 3 January, 2018 onwards.
Under MiFID we are required to provide clients with the prioritisation of execution factors and how we will handle specific client instructions, as well as the processes to monitor executions and the evidencing of compliance to our policy. These elements are included within our client disclosure statements.
Your client classification should have been communicated to you previously, and resent as part of the MiFID II Client Outreach programme.
MiFID II reiterates the MIFID requirements and specifies that we act in the best interests of clients when providing execution services and that we maintain monitoring arrangements that demonstrate compliance. We must also make disclosures to allow clients to make informed choices between competing dealers by publishing reports (under RTS 27) on execution quality and (under RTS 28) on execution venue selection.
As described in our client disclosure statements, we have provided a list of the venues upon which we place significant reliance – this list is attached. The execution venues list is maintained in parallel with our execution procedures in order to ensure the accuracy of the venues included and in order to ensure we consistently provide a high quality of execution for our clients.
