In the event of a conflict between Restoration Financial Corp. and a Client, terms expressed in English and expressed in any other language, the terms expressed in English shall prevail over those expressed in any other language.
This Requests Execution Policy (the “Policy”) is available to both retail and professional clients upon request and is also made available on our Website. The Policy serves to enable clients to make a properly informed decision about whether to utilize the services offered by the Company.
Restoration Financial Corp. (the “Company”) is a company incorporated as an International Business Company with the Financial Services Authority of Saint Vincent and the Grenadines, having the registration number 22296 IBC 2014. The purpose of this policy is to establish effective arrangements for obtaining, when the Company, is executing clients’ requests, the best possible result for its clients.
This client agreement is concluded between the Client identified by the account opening form and Restoration Financial Corp. Restoration Financial Corp. is an international business firm incorporated in Saint Vincent and the Grenadines, that provides a wide range of derivative commercial contracts.
The Company undertakes and executes request and instructions received from the Client by means of the online system, in connection with Derivative Contracts. This is a Service offered by the Company to the Client.
In accordance with the applicable regulation, the purpose of this policy is to establish effective arrangements for the Company to obtain, the best possible result for its clients, in a consistent basis when executing requests, taking into account price, costs, speed, likelihood of execution, size, nature specific instructions received from the client or any other consideration relevant to the execution of a request.
If you provide us with specific instructions as to how to execute your request, we will have complied with our obligation to take all reasonable steps to obtain the best possible result when executing that request by following your instructions. Please note that this may prevent us from following our Request Execution Policy. To the extent that your instructions are incomplete, we will usually follow our Request Execution Policy for those parts or aspects of the order not covered by your instructions.
In the absence of specific instructions from you, we will usually take into account the various execution factors and criteria set out below in order to determine how to obtain the best possible result when executing requests on your behalf.
The Company cannot guarantee that upon execution of a request the price at which the request is executed will always be better than a price which is or might has been available elsewhere.
In addition, this document aims to set out those arrangements and to ensure compliance with legislative requirements and the departmental and general procedures, and gives an overview on how requests are executed, the factors that may affect the execution’s timing and the way in which volatility determines the execution of a request.
This policy shall be read in conjunction with the Company’s Client Agreement/Terms & Conditions.
The Company solely executes requests in relation to one or more Derivative Commercial Contracts without physical delivery.
1.3 Legal Framework
This Policy implements the requirements of the applicable regulation, as this is subsequently amended from time to time.
Terms used in this Policy that are not interpreted differently shall have the meaning given to them by the Terms & Conditions of the Company.
2. Execution Policy
The Company satisfies the following conditions when carrying out client requests:
- ensures that requests executed on behalf of clients are promptly and accurately recorded and allocated;
- carries out otherwise comparable client requests sequentially and promptly unless the characteristics of the request make this impracticable, or the interests of the client require otherwise;
- Informs a retail client about any material difficulty relevant to the proper carrying out of requests promptly upon becoming aware of the difficulty.
The Company proceeds with the establishment and maintenance of a Requests Execution Policy, in order to ensure compliance with the obligation to execute requests on terms most favourable to the clients and to achieve the best possible results for its clients, taking into consideration its clients’ ability, needs and policies, where applicable and possible.
The policy outlines the process that the Company follows when executing requests, and assure taking all reasonable steps to consistently obtain the best possible result for clients through its request execution policy. It is noted however that when executing a request following a specific client instruction, the Company executes the request in line with those instructions and considers that it has discharged its best execution obligations.
Senior Management reviews the policy whenever a material change occurs that impacts the Company’s ability to continue offering best execution of its clients’ requests using the Company’s online platform.
The Company reserves the right to amend or supplement this Policy at any time.
2.2 Execution Factors
In the absence of specific client instructions, when managing client requests through to execution or upon facilitation of reception and transmission of requests the Company takes all reasonable steps to achieve the best possible result for clients in a comprehensive and consistent way. The Company takes into consideration; inter alia, a combination of the following execution factors:
- Nature of the request
- Price conditions and variations
- Likelihood of Execution and Settlement
- Any other direct consideration relevant to the execution of the request
2.3 Best Execution Criteria
The Company considers the relative importance of the abovementioned execution factors when weighted against the following execution criteria:
- The characteristics of the client;
- The characteristics of the client’s request;
- The characteristics of the Derivative Contracts that are the subject of that request;
- The characteristics of the execution venues to which that request can be directed.
The best possible result is being determined in terms of the total consideration, representing the price of the contract and the cost related to execution. The other execution factors of speed, likelihood of execution size, nature or any other relevant consideration will, in most case, be secondary to price and cost considerations, unless they would deliver the best possible result for the client in terms of total consideration.
3. Specific Instructions
In circumstances where the client provides the Company with specific instructions as to how to execute a request and the Company has accepted this instruction, then the Company executes the request in accordance with that specific instruction.
If the client provides a specific instruction to carry out a request, then by executing that request the Company complies with its duty to provide the client with best execution. This might result in being unable to follow the Company’s requests execution policy for that particular request and it is therefore noted that the specific instruction provided by the client may prevent the Company from obtaining the best possible result for the client as otherwise would be implemented according to this Policy.
4. Execution Venues
Execution venues are the entities to which the requests are placed or the entities at which Companies transmits clients’ requests for execution. In this respect, the Company acts as the Execution Venue for the execution of client’s requests in relation to DCs (Derivative Commercial Contracts or Derivative Contracts).
5. Analysis of Execution Factors
5.1.1 Pricing DCs
In regards to a given DC (Derivative Commercial Contracts or Derivative Contracts) the Company quotes the higher price at which the client can buy, thus going long (“ASK”) and the lower price at which the client can sell thus going short (“BID”) the relevant DC. The difference between the BID and ASK of a given DC is called the spread, which can vary with the different types of accounts in DCs.
The Company provides prices as are obtained from the third party external providers. In this respect prices of a given DC are calculated with respect to the underlying prices as these are provided from external sources. In respect to this is can be considered as “Outside of the market” any price quoted by the Company which differs by more than ten times the spread of that DC, in comparison with other three independent quoting sources. In such a case the Company may adjust the quoting price accordingly, or it may decide to cancel the transactions based on such prices. The Company ensures that the client receives the best execution mainly by ensuring that the price provision to the client is made with reference and compared to a range of underlying price providers and data sources. Company’s prices can be found on the Company’s platform.
In addition, the provider, is continuously updating its prices, therefore last updated prices are displayed on Company’s platform.
However, under certain conditions, as under high volatility causing rapid price fluctuations, the Company might not be in a position to execute the request placed by the client at the client’s requested price. Under this scenario, the Company maintains the right to execute the request at the first available price.
Customers may choose to transact with or without deviation from the quoted price. In conditions of high volatility and/or low liquidity, deviation mode will improve the probability of execution but may affect the pricing the Company is able to secure. The Customers may choose to deal with deviation by setting the Maximum Deviation parameter, available in the instant request execution window. If the Customers choose to deal without Deviation, if the client’s requested price differs from the best available price, the Customer’s request will be Re-quoted.
Company’s prices can be found on the Company’s platform.
Finally, and as the provider is continuously updating its prices, therefore last updated prices are displayed on Company’s platform.
When the client opens a position DC a premium or finance fee may apply. These fees may be charged either in the form of a percentage of the overall value of the executed request or as a fixed amount. In regards to the financing fees, which affect the value of the client’s open transactions these are based on daily prevailing market interest rates, which vary and details of which can be found on the Company’s website as well as on the platform. Additionally, a premium charge and a spread fee apply by the Company to DCs transactions executed. With regards to premium, a funding premium is added to the client transaction to cover the cost of the associated funding if the client holds a transaction open within the platform after a certain hour, as shown in the “Open Transactions”. With regards to the spread fee, this is the fee charged by the Company for the execution of the DC transaction, defined as the difference, in pips, between the BID and ASK price of each DC. For both premium charge and spread fee, more details may be found in the products section found on the Company’s website.
Finally, the above mentioned commissions and charges can be updated at the Company’s discretion. In this respect such changes will be subject to a notification to the clients.
All requests are placed in monetary value. The client will be able to place his request as long as he has enough available balance in his account. However, DCs transactions are leveraged which means a ratio is set that determines how much money a Client must actually place in order to open a transaction for a certain value. In addition, the leverage can also be expressed in term of what percentage the Client needs to place for a transaction. This percentage is called a margin requirement. In this respect the client may use margin to increase the potential return of a transaction, thus using leverage.
Furthermore, if the client wishes to execute a large size request, in some cases the price may become less favourable considering the feed obtained from its price provider.
Finally, the Minimum size of a request may depend on each type of DC and Client Account based on different volumes. Information on volume, minimum and maximum size of a single transaction can be found on the Company’s website.
The Company acts as the Execution Venue for the execution of requests concerning transactions in DCs. Prices may change over time. Considering that the available prices which are distributed via the Company’s platform/terminal, technology used by the client to communicate with the Company plays a crucial role. For instance, the use of a wireless connection, or dial up connection, or any other communication link that can cause a poor internet connection can cause unstable connectivity to the Company’s platform/terminal. The result for the client is to place his requests at a delay and the request to be executed at a different price offered by the Company via its platform/terminal. By taking into consideration potential threats and limitations of technology and communication issues, the Company seeks to provide high speed of execution to its clients.
5.5 Conditions and Variations
The Company’s quoted prices which are derived from its independent price providers may be affected by various factors which could also affect the above mentioned factors affecting the price of the products. The Company takes all reasonable factors to ensure the best possible result for its clients.
5.6 Likelihood of Execution
The likelihood of execution depends on whether there are available prices. However, in the event that the Company is unable to proceed with a request for any reason, including size and price, the request will not be executed. The Company is entitled, at any time and at its discretion to decline or refuse to transmit or execute any request or instruction received from the client as this is explained in the Client Agreement and General Terms & Conditions.
5.7 Likelihood of Settlement
The Company proceeds with the settlement of all transactions upon the execution and/or time of expiration of the specific transaction. In regards to DCs, the aforementioned contracts do not involve physical delivery of the underlying.
5.8 Different types of accounts in DCs
The Company offers accounts to both retail and professional clients. Different types of account are offered by the Company at which the initial level of minimum deposit, the BID-ASK spread, commission charges, percentage on return, minimum and maximum request amounts and other relevant factors vary with the account type. Relevant information on the account types can be found on the Company’s website.
6. Execution Practices in the DCs
Deviation can be defined as the difference between the expected price of a request and the price the request is actually executed at. Dealing in DCs involves deviation to appear in the normal course of activity and can appear in all types of accounts the Company offers. Specifically, deviation appears more often in periods of high volatility and illiquidity in the market thus making a request impossible to be executed at a specific price. Under the concept of deviation, the Company confirms that requests will be executed at the next best available price in relation to the price specified on the client’s request, if the Customer allows Deviation (maximum deviation).
7. Request Management
The Company ensures that, at all times, client requests are handled equitably and to client’s best advantage. Client requests are executed in a prompt and equitable manner, taking into account the nature of the request. Other similar requests may be processed or executed sequentially in parity with the time of receipt and may be aggregated or pro-rated accordingly, unless the characteristics of the request or prevailing conditions make this impracticable or the interests of the client, require otherwise.
The Company undertakes to manage all client’s requests in accordance with the following principles:
Request execution shall be prompt, fair and expeditious and processed sequentially Allocation or reallocation shall be equitable and seek to protect from client detriment.
Types of requests accepted (but not limited to):
- “Buy Limit” is a request to buy in the future, if and when the “Ask” price reaches a price specified by the Client. The current price level is higher than the price of the request placed.
- “Buy Stop” is a request to buy in the future, if and when the “Ask” price reaches a price specified by the Client. The current price level is lower than the price of the request placed.
- “Sell Limit” is a request to sell in the future, if and when the “Bid” price reaches a price specified by the Client. The current price level is lower than the price of the request placed.
- “Sell Stop” is a request to sell in the future, if and when the “Bid” price reaches a price specified by the Client. The current price level is higher than the price of the request placed.
- “Stop Loss” is a request to close a transaction if the price reaches a price specified by the Client, Stop Loss request can only be used in conjunction with an Instant Request or a Pending Request. It is intended to limit the Client’s losses. For long transactions, the price of the request can only be set below the current Bid price and when the “Bid” price reaches the price specified by the Client, the transaction is closed. For short positions, the price of the request can only be set above the current Ask price and when the “Ask” price reaches the price specified by the Client, the transaction is closed.
- “Take Profit” is a request to close a transaction if the price reaches a price specified by the Client. Take profit request can only be used in conjunction with an Instant request or a Pending Request. It is intended to secure the Client’s potential profit. For long transactions, the price of the request can only be set above the current Bid price and when the “Bid” price reaches the price specified by the Client, the transaction is closed. For short transactions, the price of the request can only be set below the current Ask price and when the “Ask” price reaches the price specified by the Client, the transaction is closed.
Client can attach to any of the aforementioned requests “Stop Loss” and/or “Take Profit” instructions to minimize loss and to secure profit, respectively.
Pending Request Modification/Cancellation: the client may modify/cancel a pending request if the price has not reached the level of the price specified by the client. The Client has no right to change or remove “Stop Loss”, “Take Profit” and “Pending Request” Request if the price has reached the level of the request’s execution or if the requested price does not differ from the market price by a minimum amount of pips (the requested price is within the ‘stops level’ limit).
Pending order execution: Limit Requests (Buy Limit, Sell Limit, Take Profit) only execute at the entry price (trigger price). If the best available price at the time of execution is not at the entry price, the request resets and waits for execution. Stop Requests (Buy Stop, Sell Stop, Stop Loss) guarantee execution but do not guarantee the specified price. When triggered, stop requests become a market request available for execution at the next available market price. Deviation may be enabled for Pending Requests, as well.
For Accounts where you are using the Hedging Setting, if you:
(a) place a Request to open a long transaction in relation to a DC, on an Account where at that time you already have on that same Account a short transaction in relation to the same DC; or
(b) place a Request to open a short position in relation to a DC where you already have a long transaction in relation to the same DC;
your instruction will instead be treated as an instruction to open the new transaction as indicated in your Request, as a hedging position.
The Company assesses on a regular basis, of particular transactions in order to determine whether it has complied with its execution policy and/or arrangements, and whether the resulting transaction has delivered the best possible result for the client.
Appropriate information is provided to the client on the content of the requests execution policy. The prior consent of the clients is obtained regarding the documented request execution policy to be followed. In addition, a clear and prominent warning is disclosed to the Company’s clients (within the Client Agreement and Terms & Conditions) that any specific instruction from a client may prevent the Company from taking the steps that is has designed and implemented in its execution policy for obtaining the best possible result for the execution of those requests in respect to the elements covered by those instructions.
Adequate information is provided to the clients through this policy in relation to the factors that are taken into consideration by the management when handling clients’ requests. Also, the policy is reviewed periodically by the Company and the clients are informed accordingly in relation to any material changes.