MiFID II

Overview

The Markets in Financial Instruments Directive (MiFID II) will enter into force on 3rd January 2018. It focuses on strengthening transparency and investor protection across the MiFID II regime via wide reaching changes to market structure, investor protection, organisational structure, and pre and post trade reporting.

MiFID II applies to those financial services businesses undertaking MiFID II business anywhere in the EU as well as those providing services cross-border. This includes investment firms, trading venues, data reporting service providers and third-country firms providing investment services or performing investment activities in or into the EU.

The GFI Group aim to continue to provide our services with as little disruption to our clients as possible. Our new venue structure is detailed in the table below. We do not currently plan to operate as an SI.

Key changes to our services are listed below:

• The GFI group are repapering clients with updated Terms of Business, Venue Rule Books, Best Execution and Order Handling and Conflict Policies.

• From 3^rd of Jan we will be unable to trade with an entity that has not provided us with a valid LEI. For more information on LEIs, please visit; http://www.gleif.org/en/.

• To meet our order record keeping obligations, we are required to collect trader short-codes from our clients to record the persons within the firm responsible for the decision or execution of trades.

• All client orders (including voice) are required to be recorded and retained at the disposal of the local regulator. Additional data will also be captured at point of order, after receiving a client order, and for operators of trading venues.

• Local Authority Clients are to be reclassified as retail from January 3^rd. All Local Authority clients wishing to continue transacting with BGC Group must request to opt-up and meet the conditions as defined by the FCA and assessed by the Firm.

• Where applicable, clients can expect to receive disclosures of; all benefits (including ongoing benefits), unbundled ‘Research’ costs (as defined under MiFID II) and all costs and associated charges related to Investment/Ancillary services and Financial Instruments.

Equivalence granted between the US and EU regulatory regimes permits US persons to execute swap transactions subject to the CFTC’s trade execution requirement on our OTF. Please note that this equivalence does not exempt US persons from their part 43 and 45 reporting obligations which remains their responsibility. GFI’s OTF will not facilitate such reporting.

Our client outreach team is actively contacting clients to collate the information necessary for us to meet our regulatory obligations including LEIs and Trader short-codes. If impacted, you will also be provided with updated legal documentation via Bloomberg Entity Exchange.

Rulebooks

GFI Brokers Ltd- Asset classes of financial instruments

GFI Securities Ltd- Asset classes of financial instruments

Ratecards

Best Execution and Order Handling Policy

Conflict of Interest Statement

Minor non-monetary benefits disclosures

Pre- and Post-Trade Transparency Reporting (RTS 1 and 2)

Best Execution Reports (RTS 27 + 28)

EMEA Terms of Business

Trading Venue Notices

Articles 32 and 52 of MiFID II establish obligations on National Competent Authorities and trading venues relating to the suspension and removal (cancellation) of certain financial instruments from trading (and any subsequent restoration).

The FCA has received notification in relation to the instrument(s) in the table below and in accordance with sections 313CB/313CC of FSMA, the FCA requires action to be taken immediately with regard to trading on these instruments on all Regulated Markets, Multilateral Trading Facilities, Organised Trading Facilities and Systematic Internalisers in the UK.

We have received a request from the FCA to SUSPEND /RESTORE/ REMOVE the instruments (below) and any associated derivatives/other instruments from trading.

The Firm will suspend trading on all venues any financial instrument that is the subject of applicable sanctions imposed by any relevant global government organisation.

Any financial instruments issued by entities that are subject to sanctions imposed due to the Ukrainian conflict are not being admitted to trading on GFI Securities OTF (“GFSO”).
For further information, please contact: #compliancebgcuk@bgcg.com.

Any financial instruments issued by entities that are subject to sanctions imposed due to the Ukrainian conflict are not being admitted to trading on GFI Brokers OTF (“GFBO”).
For further information, please contact: #compliancebgcuk@bgcg.com.

Any financial instruments issued by entities that are subject to sanctions imposed due to the Ukrainian conflict are not being admitted to trading on GFI Securities MTF (“GFSM”).
For further information, please contact: #compliancebgcuk@bgcg.com.

Any financial instruments issued by entities that are subject to sanctions imposed due to the Ukrainian conflict are not being admitted to trading on GFI Brokers MTF (“GFBM”).
For further information, please contact: #compliancebgcuk@bgcg.com.