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RIA Capital Markets Limited | Registered Office: 91 George Street, Edinburgh EH2 3ES
Registered in Scotland, No. SC226461 | Authorised and Regulated by the Financial Conduct Authority No. 219706
RIA Capital Markets Limited
Qualitative Report for Fixed Income: Debt Instruments – Bonds
This report was produced by RIA Capital Markets Limited (“RIA”) and provides a qualitative order execution
assessment for Fixed Income: Debt Instruments – Bonds, in the format described in Article 3(3) of Commission
Delegated Regulation EU/2017/576, for the period 1 January 2018 to 31 December 2018.
In line with RTS 28 RIA is required to describe how different order types determine the methods of execution
employed and decide the venues that RIA selects to source liquidity for its professional clients. The majority of
RIA’s fixed income orders were immediately marketable but with limit or guide limit prices. Depending on the
bond in question, its country of issue and its maturity, RIA’s traders exercised discretion in accessing liquidity
where appropriate. In less liquid instruments, RIA used its relationships with its counterparties, applying its
market knowledge and experience to contact the right counterparties and negotiate an optimal price. The ‘top
five’ execution venues for fixed income are detailed in the table published in this RTS 28 publication.
Eight Statements
(a) To achieve the best possible result in 2018, RIA took into account a number of execution factors, including:
Price, Size, Speed, Cost, Settlement, Likelihood of execution, Likelihood of settlement, Nature of the order.
RIA determined the relative importance of each of these factors and the manner in which each order was
executed, based on the circumstances at the time of execution, such as the type of financial instrument and
nature of the order and the execution venues to which the order could have been directed. During the period RIA
normally regarded price as the most important factor in delivering the best possible result for clients in 2018.
However, in certain circumstances where price transparency or liquidity was adversely affected, RIA gave
likelihood of execution an elevated weighting. It is often the case that likelihood of execution takes a high
priority particularly around some higher yielding and less liquid corporate bonds as opposed to government
issues. For Fixed Income RIA generally did not attach a high weighting to ‘speed.’
(b) RIA has neither close links nor any common ownership with respect to any execution venue used for this
instrument type.
(c) RIA does not have any specific arrangements with any execution venues regarding payments made or
received, discounts, rebates or non-monetary benefits received.
(d) In 2018, RIA executed orders in debt instruments on both principal and agency basis for Professional clients
primarily using BMTF for RFQs. By using BMTF we have trading access to over 30 different counterparties.
RIA has decided not to use other MTFs because it is of the opinion that by polling other MTFs for prices in the
same underlying fixed income instruments, market makers would receive the same RFQs as the majority of
bond market makers quote on the leading MTFs. RIA did not ‘transmit’ orders or ‘place’ orders with any other
bond brokers for execution.
(e) RIA’s clients are categorised as either professional clients or eligible counterparties. Best execution does not
apply to counterparties that RIA has classified as eligible counterparty.
(f) RIA does not classify any of its clients as ‘retail clients’. Therefore, any analysis around best execution
criteria weighting for orders from these clients is not applicable.
(g) The availability of meaningful (and tradeable) quotes and other datasets to aid analysis remained in short
supply. For its BMTF trades, RIA does not rely on CBBT which is formed of the weighted average prices from
contributors to Bloomberg as it believes that other than for the most liquid bonds (e.g. Government bonds),
these prices are often theoretical and not executable or reflective of the market. Where possible, RIA keeps a
record of live prices received at the time of trading and subsequent prices of executed orders. RIA was satisfied
with the level of liquidity access and choice of venues for its fixed income executions in 2018.
(h) At the time of writing (April 2019) there is no official Consolidated Tape Provider (CTP) for fixed income.