MiFID II Compliance Status: Compliant
NCA: Irish Central Bank | Last Review: July 2025 | Next Assessment: January 2026
Active Compliance
Requirement Coverage
98%
50/51 requirements met
Transaction Reports
1246K
YTD submissions
Reporting Accuracy
99.89%
acceptance rate
Categorised Clients
155
active relationships
MiFID II Compliance Pillars
| Pillar | Article | Description | Requirements | Implemented | Status |
|---|---|---|---|---|---|
Transaction Reporting | Article 26 | T+1 reporting of transactions in financial instruments to competent authorities | 8 | 8 | Compliant |
Best Execution | Article 27 | Taking all sufficient steps to obtain the best possible result for clients | 6 | 6 | Compliant |
Client Categorisation | Article 4 | Classification of clients as retail, professional, or eligible counterparties | 4 | 4 | Compliant |
Suitability & Appropriateness | Article 25 | Assessment of client knowledge, experience, and investment objectives | 7 | 7 | Compliant |
Product Governance | Article 16(3), 24(2) | Product approval process, target market identification, distribution strategy | 6 | 5 | Partial |
Inducements & Costs | Article 24 | Disclosure of costs, charges, and inducements | 5 | 5 | Compliant |
Conflicts of Interest | Article 23 | Identification, prevention, management, and disclosure of conflicts | 4 | 4 | Compliant |
Record Keeping | Article 16(6) | Retention of records including telephone conversations and electronic communications | 5 | 5 | Compliant |
Algorithmic Trading | Article 17 | Systems, controls, and risk management for algorithmic trading | 6 | 6 | Compliant |
| Total | 51 | 50 | 98.0% |
Transaction Reporting
Total Reports (YTD)1,245,892
Acceptance Rate
99.89%
Rejected Reports1325
ARM ProviderARM: Unavista
Best Execution
Execution Policy
Active
Venue Analysis
Quarterly
RTS 28 Report
Published
Quality ReviewMonthly
Costs & Charges
Ex-Ante Disclosure
Active
Ex-Post Disclosure
Active
Total Ongoing Charges0.90%
Annual StatementMarch 31
Client Categorisation
Professional Clients
89 clients
$2.45B
Assets Under Management
Includes: Credit institutions, Investment firms, Insurance companies +2 more
Eligible Counterparties
24 clients
$1.85B
Assets Under Management
Includes: Central banks, Supranational organisations, National governments
Retail Clients
42 clients
$0.38B
Assets Under Management
Includes: High Net Worth Individuals, Trusts, Family offices (electing retail)
Top Execution Venues (RTS 28)
| Venue | Type | Volume Share | Avg Execution | Price Improvement |
|---|---|---|---|---|
| London Stock Exchange | Regulated Market | 32% | 2.3ms | +0.02% |
| Euronext Paris | Regulated Market | 24% | 2.8ms | +0.01% |
| Deutsche Börse Xetra | Regulated Market | 18% | 2.1ms | +0.03% |
| CBOE Europe | MTF | 14% | 1.9ms | +0.02% |
| Turquoise | MTF | 8% | 2.0ms | +0.04% |
| Systematic Internaliser | SI | 4% | 1.5ms | +0.01% |
Product Governance Overview
| Product | Target Market | Risk (1-7) | Cost Ratio | Last Review | Status |
|---|---|---|---|---|---|
| Global Equity Fund | Professional | 5/7 | 0.85% | October 2025 | Approved |
| Fixed Income Portfolio | Professional, Retail | 3/7 | 0.45% | November 2025 | Approved |
| Alternative Strategies Fund | Professional | 6/7 | 1.50% | September 2025 | Approved |
| Multi-Asset Balanced | Professional, Retail | 4/7 | 0.65% | November 2025 | Approved |
MiFID II Reporting Requirements
Transaction Reporting (Article 26)
Investment firms must report complete and accurate details of transactions in financial instruments to the competent authority no later than the close of the following working day (T+1).
RTS 28 Best Execution Report
Annual publication of top five execution venues for each class of financial instruments, along with information on execution quality obtained. Due by April 30 each year.
Cost & Charges Disclosure
Ex-ante disclosure before providing services and ex-post annual statement showing cumulative effect of costs on return. Includes all costs, charges, and inducements.
Competent Authority
- NCA: Irish Central Bank (CBI)
- ARM: Unavista (LSE Group)
- APA: Not applicable (no SI trades)
- Last NCA Communication: October 2025
Key Deadlines
- Transaction Reports: T+1
- RTS 28 Report: April 30, 2026
- Annual Cost Statement: March 31, 2026
- Product Review: Annually minimum