Best execution policy: cash funds

Background

This document sets out CCLA’s Order Execution Policy and approach to providing ‘best execution’ for the Cash Funds and Segregated Clients (‘Cash Funds’) managed by CCLA IM and FM on behalf of its clients. For the purpose of this policy, the term ‘client’ will also be used to mean ‘scheme’ or ‘prospectus’ and are therefore deemed to be professional.

When placing deposits with banks and building societies it is not feasible to adhere to the Best Execution Policy for quoted securities. This is principally because transactions in money market instruments are made over the counter on a Trading Facility or with an Execution Venue and are usually indicative. It’s only at the point of agreement between the seller, usually the issuer, and the purchaser is the transaction is binding. In some but not all occasions, a broker is used as an intermediary between the issuer and the purchaser on a Trading Facility.

Under the EU Money Market Fund Regulation 2017/1131, the COIF Charities Deposit Fund is categorised as a short-term LVNAV Money Market Fund.

The Public Sector Deposit Fund is a UK short-term LVNAV Qualifying Money Market Fund.

Eligible financial instruments

When applying best execution obligations, CCLA takes into account the different circumstances surrounding the execution of orders for particular types of financial instruments. Eligible financial instruments comprise of transferable securities (e.g. equities & bonds), money market instruments (e.g. certificates of deposit), units in regulated collective investment schemes, options, futures and other financial derivatives.

For clarity, eligible financial instruments do not include cash accounts, money market deposits, direct property and unregulated collective investment schemes.

Execution venues

Execution venues are the centres through which securities transactions are ultimately facilitated. These include the major Regulated Markets, Multilateral Trading Facilities (MTF), Organised Trading Facilities (OTF), Systematic Internalisers (a firm that deals on its own account), the UK Money Market, third-party investment firms (brokers acting as market makers or other liquidity providers) and the managers of Collective Investment Schemes.

CCLA is not a direct member of a Regulated Market or a Multilateral Trading Facility and uses approved brokers to transact on its behalf or deals directly with its approved deposit takers (in the case of most money market instruments). CCLA’s approved brokers are deemed to operate an OTF or MTF and the approved deposit takers are deemed to be the Execution Venues for the purpose of this Policy.

Remuneration, discounts or non-monetary benefits are not received by CCLA for routing client orders to a particular execution venue.

On an annual basis CCLA will publish the top five brokers in terms of trading volumes chosen for execution. This will be provided for each class of financial instruments and will include a summary on the quality of execution obtained.

CCLA’s list of approved brokers and deposit takers can be found at the end of this policy.

Types of UK money markets

Our funds will typically use money market deposits which include, but are not limited to, Call Accounts, Notice Accounts, Fixed Term Deposits and Certificates of Deposit.

Method of execution

Having assessed the relevant factors and any specific instruction provided by a client, CCLA will select the most appropriate venue(s) from those available and execute the order accordingly.

Best execution policy

After satisfying the Fund’s primary and secondary objectives of security and liquidity respectively, price (or yield) will be the most important execution factor when making a choice between Execution Venues. Other factors including likelihood of settlement, diversification of issuer, and size of ticket will also be a consideration.

When placing a deposit with an issuer CCLA aims to achieve the best price possible (i.e. highest yield) relative to other issuers of similar credit quality and for the same instrument type and period. To achieve this CCLA receives daily indications of issuer yields for different instruments and periods from a number of sources including brokers and directly from issuers. CCLA also maintains a sufficiently long list of approved issuers in order to ensure flexibility to deal with a number of potential issuers.

When selling Certificates of Deposit in the secondary market the same principles will apply although the best possible price will be the lowest yield and significant consideration will be given to market illiquidity.

Where CCLA transmits an order to an approved broker for execution it will look to use its experience in order to improve the terms on which it transacts in that market. CCLA looks to use the execution venue best placed to help the firm add value to any transactions. CCLA does not pay commission on its money market deposit transactions to trading and execution venues.

Monitoring and review of the best execution policy

CCLA will review the policy at least annually and whenever a material change occurs that affects CCLA’s ability to continue to obtain the best possible result for the execution of client orders. Updated versions of this document will be posted on our website (www.ccla.co.uk).

Approved deposit takers (execution venues)

ABN Amro Bank N.V.
Australia and New Zealand Banking Group Limited
Bank Nederlandse Gemeenten (BNG)
Bank of America N.A.
Bank of Montreal
Bank of New York Mellon (The)
Bank of Nova Scotia (The)
Bank of Scotland plc
Barclays Bank UK plc
Barclays Bank plc
Bayerische Landesbank
BNP Paribas
Canadian Imperial Bank of Commerce
Citibank N.A.
Commonwealth Bank of Australia
Coventry Building Society
Credit Agricole Corporate and Investment Bank
Credit Industriel et Commercial
Danske Bank AS
DBS Bank Limited
DNB ASA
Deutsche Zentral-Genossenschaftsbank (DZ Bank AG)
Government of the United Kingdom
Handelsbanken plc
HSBC UK Bank plc
HSBC Bank plc
ING Bank N.V.
JP Morgan Chase Bank N.A.
KBC Bank N.V.
Landesbank Baden-Wuerttemberg
Landesbank Hessen-Thueringen Girozentrale
Leeds Building Society
Lloyds Bank plc
Lloyds Bank Corporate Markets plc
Mizuho Bank
MUFG Bank
National Australia Bank Limited
National Bank of Canada
Nationwide Building Society
NatWest Bank plc
NatWest Markets plc
Nordea Bank AB
Overseas-Chinese Banking Corporation
Rabobank
Royal Bank of Canada
Santander UK plc
Skandinaviska Enskilda Banken AB
Societe Generale
Standard Chartered Bank plc
SMBC Bank
SMBC Bank International
Toronto-Dominion Bank (The)
UBS AG
United Overseas Bank Limited
Westpac Banking Corporation
Yorkshire Building Society

Approved brokers (on OTF or MTF)

BGC
ICAP Securities Limited
RP Martin a division of BGC
Tradition
Tullett Prebon Securities

December 2020