1. Introduction
Luna Wealth Asset Management (hereinafter, the “Company”) is a Cyprus Investment Firm incorporated and registered under the laws of the Republic of Cyprus, with registration number HE377224. The Company is authorised and regulated by the Cyprus Securities and Exchange Commission (hereinafter the “CySEC”) under the license number 379/19.
This is the Execution Quality Summary Statement (hereinafter, the “Statement””) of the Company, pursuant to the requirement of disclosure of such information under Regulation EU 2017/576 supplementing MiFID II (2014/65/EC) and the Regulatory Technical Standards 28 of the Commission Delegated Regulation of 08/06/2016.
The Company is required to inform all its Retail and Professional Clients about all sufficient steps taken to obtain the best possible result for its Clients (hereinafter the “best execution”); either when executing Client orders or receiving orders for execution in relation to financial instruments on behalf of Clients. This Statement is a summary of those steps taken by the Company in addition to those referred to in the Order Execution Policy of the Company. Moreover, an analysis and conclusions derived by the monitoring undertaken with respect to Clients orders’ execution on the execution venues utilized by the Company within the year 2022 is included.
2. Application
The Company’s Order Execution Policy, which ensures best execution, applies to Retail and Professional Clients only.
In applying its Order Execution Policy, the Company determines the best possible result in terms of total consideration. Total consideration is the price of the financial instrument concerned and the costs payable by the Client as a result of execution. These costs include all expenses incurred that are directly related to the execution of the order, such as execution venue fees, clearing and settlement fees and any other fees paid to third parties involved in the execution of the order. When applying the Order Execution Policy price merits a relatively high importance. In considering price, we also consider the steps that the Company may reasonably take to minimize the market impact of execution. The Company takes other execution factors into account where they are instrumental in delivering the best possible result for the Client. For example, in the case of highly illiquid instruments, speed and likelihood of execution becomes a paramount factor. Finally, the application of the best execution is subject to prevailing market conditions and our understanding of the Client’s preferences. Therefore, there may be circumstances in which the Company concludes that other execution factors are as important, or more important, than price in applying the best execution. It should be noted though that the application of the Order Execution Policy and the best execution principle is neither a guarantee that the best price will be obtained nor a guarantee that the transaction will be executed in full.
3. Relative Importance of Execution Factors During 2022
For the assessment of execution of Clients’ Orders the Company takes into consideration the following factors:
- 1.the price
- 2.the cost
- 3.the speed of execution
- 4.the possibilities of execution and settlement
- 5.the volume
- 6.the nature, characteristics and the specificities of the order received
- 7.any other factor that relates to the execution.
You may refer to the Order Execution Policy of the Company for further details on the above.
4.Execution Venues Used by the Company
The Company during 2022 cooperated and routed orders to the execution venue(s) listed below:
| No. | Execution Venue | Country | Commencement date | End date | |||||
|---|---|---|---|---|---|---|---|---|---|
| 1 | SOVA Capital (UK) Ltd | United Kingdom | 20/03/2020 | 03/03/2022 | |||||
| 2 | J.P. Morgan SE | Germany | 27/11/2020 | ||||||
| 4 | Atonline Ltd | Republic of Cyprus | 21/02/2020 | ||||||
| 5 | VP Bank (Schweiz) AG | Switzerland | 12/02/2020 | ||||||
| 9 | Bank Julius Baer & Co Ltd | Switzerland | 23/12/2021 | ||||||
| 10 | Market Securities (Dubai) Limited | United Arab Emirates | 22/07/2022 | ||||||
In selecting an execution venue for the execution of a transaction, the Company took into account the following in respect of the venue concerned:
- price
- cost of execution
- liquidity available for the financial instruments concerned
- speed of execution
- reliability of the venue
- continuity of trading
- creditworthiness – good standing of the venue
- quality of any related clearing and settlement facilities, and
- such other factors as we consider relevant to the application of the overarching principle of best execution. The primary execution factors considered were immediate price and cost. The Company also considers liquidity, credit quality and likelihood of settlement as important factors in a significant amount of orders.
It should be noted that 2022 was a year affected by global geopolitical developments and the extensive sanctions regime imposed on the Russian Federation by the EU, US, UK and UN. The Company was specifically impacted due to the effect of the sanctions on its prime broker. Sova Capital Ltd was the Company’s prime broker/primary execution venue and entered into a special administration regime on the 03.03.2022, at its own initiative, in order to resolve liquidity issues that arose due to the imposition of the sanctions. The knock-on effect of the special administration process was that assets were frozen and trading activity ceased until the conclusion of the process; thus limiting the trading activity of the Company as an unintended consequence. Finally, the vast majority of Clients’ assets and funds were transferred during the months of November and December 2022 to Market Securities (Dubai) Ltd, who has assumed the prime broker role for the Company.
5. Changes in Execution Venues
The Company has amended its execution venues listed in the Company’s execution policy in 2022. The Company continues to take steps to establish business relationships with additional brokers and venues to further enhance the quality of execution offered to Clients.
6. Conflicts of Interest
The Company does not maintain close links and common ownership structures with any execution venues.
The Company implements and has in place sufficient measures to mitigate such potential conflicts. For additional information please refer to the Conflicts of Interests Policy disclosed on the Company’s website.
7. Payments of Non-Monetary Benefits Between the Company and its Execution Venues
The Company does not receive any payment or non-monetary benefit from any execution venue in exchange for routing client’s orders to said execution venue.
8. Execution Quality Data Tools
The Company does not currently use any specific tools.
9. Consolidated Tape Provider Use under Art.65 Directive 2014/65/EU
Currently not applicable to the Company.
10. On-going Monitoring
The Company monitors the arrangements described in this Statement in order to identify any deficiencies and to assess whether any changes should be made. This monitoring includes the monitoring of the performance of connected parties and other third parties which we may engage in the future to transmit Client orders to.
The Company monitors on an ongoing basis its execution arrangements by checking the orders executed and evaluating them. The Company’s Trading Department is monitoring the above and reports to the Senior Management of the Company.
Finally, the above monitoring procedure is under the review of the Control functions of the Company, namely the Compliance and Internal Audit functions, which report directly and independently to the Board of Directors of the Company their findings and recommendations on an annual basis.