Moneybox Order Transmission Policy
1.1 What’s the Order Transmission Policy?
This document sets out how we deal with any order instructions we receive from you to buy or sell investments, which we transmit to third party brokers in order to execute on our behalf.
When we say “Moneybox”, “we”, “us” or “our” in this policy, we’re referring to Digital Moneybox Limited.
This Order Transmission Policy applies to any person who opens an account with us. When we say “you” or “your” in this policy, we mean that person.
1.2 How an instruction to place an order works
You can place orders to buy and sell investments through the Moneybox app.
We offer access to investments through our products, but we don’t physically invest your money ourselves.
Once we receive your instruction to place an order, we send it to a third party, known as a broker, who specialises in placing investment orders with trading venues. This means that we are part of the chain that takes your order and finds the right place to execute it, and because that involves a certain amount of discretion about what the “right place” might mean for you, we are required by the Financial Conduct Authority to act in your best interests and to take all sufficient steps to obtain the best possible result for you.
1.3 What this document includes
This document describes what we mean when we say “best possible result for you” and tells you how we achieve it.
2. GIVING US CONSENT
Before we can provide any order transmission services we need your consent to take your order instruction and do what we need to do with it in order to place it.
By opening an account with us you agree to this policy.
You also consent to the best execution arrangements of our UK Broker, Winterflood Securities, which you can read at Winterflood Execution Policy, and to the best execution policy of our US Broker Dealer, DriveWealth LLC, which can be made available to you on request.
3. EXECUTION FACTORS
Not every order execution is the same. In some cases, it’s better to be able to place the order quickly. In others, it’s more important to get the best price possible. There is a range of factors to balance when providing you with the best possible result on your order execution. They include:
- The price of the investment.
- The costs associated with the transaction.
- The likely speed of getting the transaction done.
- The likelihood of execution and settlement.
- The size and nature of the order.
- Any other consideration that is relevant to the execution of the order in question (including market impact).
Of these factors, price and costs are generally the key factors we consider, though the overall benefit of a particular transaction could be affected by other factors too. As a result, any orders we pass to our brokers may not always have the best headline price.
When we look at the relative importance of these factors we always take into account:
- The fact that we classify you as a retail customer.
- The characteristics of the particular order, and the characteristics of the investment that is subject to that order.
- The characteristics of the execution venues on or with which the order can be placed.
4, ACTING ON YOUR INSTRUCTIONS
We are responsible for arranging for the execution of any order instruction we receive from you via the Moneybox app. First, you provide us with an instruction. Then we pass the order on to our UK Broker, Winterflood, or US Broker Dealer, DriveWealth, as applicable, and they arrange for execution and settlement.
The Moneybox Terms and Conditions (Section 5.2 (Order Instructions)) sets out the process and timings when you place an order instruction with us.
If you give us specific instructions about an order you’ve placed, then we’ll act on your instruction (so long as our internal processes and timings permit) even if it means that the execution of your order isn’t on the most favourable terms.
You should note that we won’t give you advice on the investment transactions you enter into. That includes telling you whether a specific instruction is a good idea or not.
5. ORDER AGGREGATION
We aggregate orders.
Order aggregation is when we combine a number of customer orders together so that we can obtain generally more favourable outcomes including, for example, lower transaction charges.
When we do aggregate the orders of multiple customers together we will always follow our.
Please note that aggregating orders in this way may cause some individual customers to be worse off than if we hadn’t aggregated the order. But generally, the outcomes should be better.
6. ORDERS IN UK FUNDS
Through Moneybox you have access to UK mutual funds, UK exchange traded funds, UK life funds and any other UK funds as may be available through the Moneybox app from time to time. You can trade these on an execution-only basis, which means we simply execute any order instructions you give us and don’t provide you with any advice or guidance about the stock in question.
When we receive your order instructions we’ll send them on to our appointed UK Broker, Winterflood, for execution. Winterflood is authorised and regulated by the Financial Conduct Authority, and therefore owes a duty of best execution in respect of the deals it executes for us on your behalf.
We chose Winterflood after fully reviewing its dealing arrangements and satisfying ourselves that its order execution policy considers all of the execution factors we care about and places appropriate relative importance on each of them in a way that corresponds with this policy. In our view, we believe that we’ll get results that are at least as good as from other alternative providers or arrangements. We monitor Winterflood on an ongoing basis to ensure that remains the case.
If an order is for a non-exchange traded open ended investment fund, otherwise known as a mutual fund, it can only be executed through the operator of the fund and, therefore, there is only one venue on which Winterflood is able to execute your order.
If an order is for a fund that is traded on exchanges then it will be sent by Winterflood to a retail service provider to be executed.
Sometimes Winterflood will need to hold your client money in order to execute transactions on your behalf. Where they do, they will hold the money in a client money account.
Winterflood may also sell some of the assets it holds for you in order to recover any debts relating to those assets, but it can only do this in ways that are permitted in the Financial Conduct Authority’s rules.
7. ORDERS IN US STOCKS
Through Moneybox, you have access to a selection of US stocks that are listed on the New York Stock Exchange and the Nasdaq Stock Market. You can trade these on an execution-only basis, which means we simply execute any orders you give us and don’t provide you with any advice or guidance about the stock in question.
If you place a buy or sell order for any of these stocks, we’ll send that order to our US Broker Dealer, DriveWealth.
DriveWealth is registered with the Securities and Exchange Commission. It is also a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation.
We chose DriveWealth after fully reviewing its dealing arrangements and satisfying ourselves that its own order execution policy considers all of the execution factors we care about and places appropriate relative importance on each of them in a way that corresponds with this policy. In our view, we think we’ll get results that are at least as good as from other alternative providers or arrangements. We monitor DriveWealth on an on-going basis to ensure that remains the case.
We believe that having a relationship with just one broker dealer in the US is in the best interests of our customers and will allow us to achieve the best possible results on a consistent basis.
DriveWealth is not an executing broker except for transactions in fractional shares. Instead, it passes all orders received to another broker-dealer for execution. However, DriveWealth still owes its clients a duty of execution. The duty, derived from the rules of the Securities and Exchange Commission, requires it to seek to execute customer trades at the most favourable terms reasonably available under the circumstances.
DriveWealth monitors its trade routing through its Best Execution Oversight Group, which reviews the quality of executions. These reviews look at the characteristics of the market that the securities were traded on, the size of the order, the speed of execution, the number of potential markets that were checked, the terms and conditions of the order placed and the accessibility of the quotation.
Sometimes DriveWealth will need to hold your money in order to execute transactions on your behalf. Where they do, they will hold the money in a segregated account.
DriveWealth may also sell some of the assets it holds for you in order to recover any debts relating to those assets, but it can only do this in ways that are permitted in accordance with applicable rules and regulations.
8. FRACTIONAL HOLDINGS
When you submit a buy order for a particular fund or stock through the Moneybox app, you choose to invest a particular cash amount (say £100). Because the price of the fund or stock may not always divide equally into the cash amount, you may end up with fractional holdings.
When you place a sell order for a particular fund or stock through the Moneybox app, you choose to sell a particular cash amount (say £100). Again, because the price of the fund or stock may not always divide equally into the cash amount, this may involve the sale of a fraction of a share or stock.
9. MINIMUM ORDER VALUE
Buy and sell orders for stocks and funds may have a minimum order value, which can change from time to time.
10. CURRENCY CONVERSION
If you place a buy or sell order for a fund or stock that’s denominated in a currency other than £ Sterling, we’ll convert to or from that currency at the exchange rate available at the relevant time in the Moneybox process so that we can facilitate the settlement of that transaction.
For buy orders for US stocks, we will convert from £ Sterling to US Dollars following your buy instruction to then pass on to our US Broker Dealer, DriveWealth.
For sell orders, we will pass on your order to sell to our US Broker Dealer, DriveWealth. Once the order has settled and we receive the US Dollar, we will convert the money to £ Sterling.
11. MONITORING THIS POLICY
We’ll regularly review the effectiveness of this policy at least annually and correct any deficiencies we identify.
We’ll also review the policy if something material happens that affects our ability to keep getting the best possible execution results for our clients. That may also include making changes to the people we rely on to help you achieve best execution.