RTS28 REPORT
RC Brown Investment Management PLC
We note below the information required to be provided under Article 3(3) of RTS 28 providing a summary of the analysis and conclusions drawn from RC Brown’s detailed monitoring of the quality of execution obtained on the execution venues where they executed all client orders in the previous year.
| Requirement under Article 3 (3) | RC Brown responses |
| (a) an explanation of the relative importance the firm gave to the execution factors of price, costs, speed, likelihood of execution or any other consideration including qualitative factors when assessing the quality of execution; | The execution factors considered to be most important in the achievement of best execution by RC Brown are price and ability to deal in the necessary size. Business is therefore allocated to brokers on the basis of their ability to execute orders at competitive prices and volumes. Speed and likelihood of execution are also considered and in certain circumstances may be considered most important depending on specific client circumstances. |
| (b) a description of any close links, conflicts of interests, and common ownerships with respect to any execution venues used to execute orders; | RC Brown does not have any close links, conflicts of interests or common ownerships with respect to any execution venues used to execute orders. |
| (c) a description of any specific arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received; | The Firm does not have any arrangements with any execution venues regarding payments made or received, discounts, rebates or non-monetary benefits received. |
| (d) an explanation of the factors that led to a change in the list of execution venues listed in the firm’s execution policy, if such a change occurred; | This is the first Report and there are no changes to note in the list of execution venues listed in the firm’s Execution Policy. |
| (e) an explanation of how order execution differs according to client categorisation, where the firm treats categories of clients differently and where it may affect the order execution arrangements; | All RC Brown clients are treated the same under its Execution Policy. |
| (f) an explanation of whether other criteria were given precedence over immediate price and cost when executing retail client orders and how these other criteria were instrumental in delivering the best possible result in terms of the total consideration to the client; | This is not applicable to RC Brown as it does not execute retail client orders. |
| (g) an explanation of how the investment firm has used any data or tools relating to the quality of execution, including any data published under Delegated Regulation (EU) 2017/575 [RTS 27]; | RC Brown regularly monitors the quality of execution obtained by its execution venues (brokers) and are satisfied that it has adhered to the requirements set out in its execution policy in seeking to obtain best execution for its clients.
Each trade is monitored by the Fund Managers. It is a prerequisite of the terms of business of all brokers used by RC Brown that they must provide our clients with best execution. RC Brown has access to quarterly information from the broker analysing indicating how they have performed in relation to best execution in relation to price against others in the market.
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| (h) where applicable, an explanation of how the investment firm has used output of a consolidated tape provider. | This is not applicable as RC Brown does not use the output of a consolidated tape provider. |