What is changing

MiFIDII increases the scope of transaction reporting, in terms of reportable fields and reportable asset classes. It also places obligations on buy side clients to perform their own transaction reporting, unless they use a model of receiving and transmitting (R&T) of orders. 

Peel Hunt Approach

Peel Hunt already transaction reported under MiFID I, meaning our focus has been on upgrading processes and reference databases to cater for the new fields. New information we need from clients:

• Legal Entity Identifier (for all entity clients)
• Natural Person IDs (for all private/custody clients)

This information has been requested from all clients as part of our MiFIDII papering exercise. Please respond to any communication you have received or for assistance contact clientonboarding@peelhunt.com

What does this mean for me?

Peel Hunt transacts in the DEAL capacity under MiFID II, as this best reflects the nature of our business. The diagram below shows how this operates in the case where a client has given an order to Peel Hunt to buy 15,000 VOD.L.

This model has the benefit of only requiring our clients to transaction report at the order level, rather than fill (as would be the case under a MTCH capacity). It also means that no personal or sensitive information will be required from clients, as both the investment and decision maker will be internal to Peel Hunt.

A number of clients have asked whether we intend to support delegated or assisted transaction reporting under MiFID II. Likewise, others have asked whether we intend to enter into receipt and transmission agreements with clients. The operational complexity of these arrangements, along with the requirement to transmit personal and sensitive client details, make them undesirable for both clients and brokers. For these reasons, we will not support delegated, assisted or ‘receipt and transmission’ based models.