Order Execution Policy
Version 1 - 30 December 2024
1. Background
This document describes the order handling and best execution of orders by Lightyear U.K. Ltd.
We are Lightyear U.K. Ltd, a private limited company incorporated in England and Wales (company number 14367910) with our registered address at:
256-260 Old Street, London EC1V 9DD United Kingdom.
256-260 Old Street, London EC1V 9DD United Kingdom.
Lightyear U.K. Ltd (hereinafter referred to as “Lightyear,” “we,” or “us”) is authorised and regulated by the Financial Conduct Authority ("FCA") under firm reference number 987226.
Unless specified otherwise, all definitions are adopted from Lightyear Terms of Service which are available on our website.
2. Purpose
This policy sets out our approach to order handling and best execution of orders in accordance with our regulatory obligations (the “Policy”).
When you place orders with us, you consent to your orders being executed and/or transmitted for execution as described in this Policy.
2.1. Investment Services
Lightyear provides the following investment services:
- Execution of orders on behalf of clients: Acting to conclude agreements to buy or sell instruments on behalf of customers.
- Reception and transmission of orders: Receiving customer orders and passing them to a broker for execution or onward transmission.
For simplicity, in this Policy, the term “execution of orders” includes the service of “reception and transmission of orders,” unless stated otherwise.
2.2. Policy Objectives
This Policy explains:
- The steps Lightyear takes to ensure customer orders are executed.
- The circumstances under which we are obligated to ensure the best possible result for our customers (“best execution”).
3. Order Handling and Aggregation
We have implemented procedures to ensure the prompt, fair, and expeditious execution of orders.
3.1. Order Types
You may place the following types of orders via the Lightyear App:
- Market Orders (including Repeat Orders)
- Limit Orders
- Stop Orders (when available)
Market Orders are sent for execution immediately unless:
- Manual handling is required due to the order’s nature or size.
- The instrument is traded OTC.
- The relevant market is closed at the time of the order.
3.2. Aggregation of OTC Orders
- OTC orders may be aggregated and executed only at specific times during the day.
- Aggregation is handled carefully to ensure no customer is disadvantaged.
3.3. Fractional Orders
- Orders for instruments are executed on a whole basis.
- Fractional orders may be aggregated with other customer orders.
- Broker may execute fractional orders on its own account to facilitate execution.
4. Execution Services
Execution Methods
- Trading Venues
- Orders may be executed directly on trading venues or indirectly via a third-party broker.
- Third-Party Brokers
- Brokers without membership on a trading venue may use a third-party broker for execution (e.g., US instruments).
- OTC Transactions
- Instruments not traded publicly are executed OTC with a third-party partner (e.g., issuer or distributor).
- Broker Acting as Counterparty
- For fractional trading of EU/UK instruments, the broker acquires full instruments and executes fractional parts from its own book.
5. Best Execution
Execution Factors
To ensure the best execution, we consider the following factors:
- Price: The price at which an instrument is executed.
- Costs: Including market impact and explicit fees.
- Speed: Time taken to execute an order.
- Likelihood of Execution/Settlement: Probability of completing the order.
- Size: Order size and its impact on execution.
- Nature of Transaction: Characteristics influencing execution.
Total Consideration
For retail and professional clients, total consideration (price + costs) is the primary execution factor.
6. Execution Venues and Selection
We execute customer orders using:
- Regulated Markets
- Multilateral Trading Facilities
Venue Selection Criteria
Venues are selected based on:
- Market share
- Likelihood of execution and settlement
- Cost of execution
- Order transmission speed
- Venue features
7. Specific Instructions
If a customer provides specific instructions, we execute or transmit the order accordingly. These instructions may prevent us from ensuring the best execution as per this Policy.
8. Monitoring and Review
Broker and Venue Review
- Lightyear reviews broker execution activity and selected venues at least annually.
- Market landscape reviews are conducted for potential alternative brokers and venues.
Policy Review
We review this Policy annually to:
- Identify and implement necessary amendments.
- Ensure the Policy reflects applicable law changes.
- Notify customers of material changes as per the Terms and Conditions.
9. Inducements
- We do not structure or charge commissions unfairly.
- Inducements from third-party partners comply with FCA rules.
10. Consent
By agreeing to the Agreement, customers are deemed to consent to this Policy.
11. Responsibilities
Our duty to provide best execution does not imply fiduciary responsibilities beyond specific regulatory obligations. Customers remain responsible for their investment decisions.
12. Further Questions
For any questions about this Policy:
- Email: support@lightyear.com
- Mail: 256-260 Old Street, London EC1V 9DD