Client Documentation and Disclosures

EMIR Documentation

Sucden Financial Limited (“Sucden”) services include clearing derivatives through central counterparties (“CCPs”) in the European Union. Consequently, the European Markets Infrastructure Regulation (“EMIR”) requires us to publicly disclose the costs, protection levels and risks associated with the various types of clearing account models/segregation levels that we are required to offer pursuant to the regulation.

Please note that the Clearing Member Disclosure Document and Pricing Disclosure for Clearing Account Structures document are subject to change. Accordingly, please check back to this site regularly to monitor for updates.

The Clearing Member Disclosure Document sets out these details:

MIFIDPRU 8 Disclosures

MiFID II RTS 28 Reporting

Information on the quality of execution obtained for client orders in 2020


This document contains a summary of the analysis and conclusions that Sucden has drawn from its monitoring of the quality of execution obtained on the execution venues where it has executed client orders in 2020.


All client orders where Sucden owes the client best execution under the Markets in Financial Instruments Directive 2014/65/EU (“MiFID II”). For a detailed breakdown of the asset classes for which Sucden Financial Limited (“SFL”) owes a duty of best execution, please refer to the Order Execution Policy at:

Information required to be disclosed under Regulatory Technical Standard 28 of MiFID II

a) An explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution.

In selecting the appropriate Execution Venue for a specific transaction, SFL considers the following execution factors:

  • available price in the market;
  • transaction costs (including commission, execution, clearing and settlement costs);
    speed of execution;
  • the likelihood of execution and settlement (depending on liquidity in the particular market);
  • the size and nature of the transaction; and
  • Any other consideration that SFL deems to be relevant to the execution of that transaction.

SFL takes into account the following criteria when determining the relative importance of the abovementioned execution factors:

  • characteristics of the client;
  • characteristics of the client’s order (e.g. market, limit, stop);
  • characteristics of the financial instrument(s) (e.g. commodity, currency, fixed income, equity);
  • characteristics of the Execution Venues to which the order can be directed.

In general, SFL regards price as being the most important execution factor when seeking to obtain the best possible outcome for clients. However, in certain circumstances SFL may decide in its absolute discretion that the other factors mentioned above are more important than price.

A description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders.

SFL may execute orders internally. These orders will only be internalised when it is determined, in accordance with SFL’s Order Execution Policy and taking into account potential conflicts of interest, that SFL is the appropriate Execution Venue. Orders will be internalised when, after consideration of the execution factors, SFL’s internal execution is expected to provide the best result for the client. SFL does not have any close links or common ownership with respect to any external execution venues.

A description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received.

Under SFL’s Order Execution Policy, it must not receive any remuneration, discount or non-monetary benefit for routing orders to a particular Execution Venue as this could give rise to a conflict of interest between the benefit received by SFL and its obligation to achieve the most favourable terms for the client.

An explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred

There were no changes to the execution venues listed in the Order Execution Policy during 2020.

An explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements.

SFL does not provide investment services to retail clients. SFL will apply Best Execution to transactions with Professional Clients dealing in Financial Instruments where it accepts an order or where it has expressly agreed to provide Best Execution. SFL’s Order Execution Policy does not apply to Eligible Counterparties; accordingly, we will not owe Best Execution in transactions entered into with Eligible Counterparties. However, this does not diminish SFL’s obligation to act honestly, fairly and professionally and to communicate in a way that is fair, clear and not misleading when dealing with Eligible Counterparties.

An explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client.

SFL does not provide investment services to retail clients.

g) An explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under RTS 27.

SFL uses an automated surveillance system called NASDAQ SMARTS to identify situations where the house trades ahead of a client at the same or better price. The data published under RTS 27 was not available for the calendar year of 2020.

h) Where applicable, an explanation of how the investment firm has used output of a consolidated tape provider established under Article 65 of Directive 2014/65/EU.

Not applicable.