Regulatory Information


Fisher Investments Europe


Fisher Investments Ireland Limited is a private limited company incorporated in Ireland that trades under the name Fisher Investments Europe (“Fisher Investments Europe”). Fisher Investments Ireland Limited and its trading name Fisher Investments Europe are registered with the Companies Registration Office in Ireland under numbers 623847 and 629724. Fisher Investments Europe is regulated by the Central Bank of Ireland (“CBI”). Fisher Investments Europe’s registered address is: 2nd Floor, 3 George’s Dock, International Financial Services Centre, Dublin 1, D01 X5X0 Ireland. You can check this on the CBI’s register by visiting the CBI’s website http://registers.centralbank.ie/ or by contacting the CBI at +353 1 2246000. The CBI’s address is New Wapping Street, North Wall Quay, North Dock, Dublin 1, D01 F7X3, Ireland.

Fisher Investments Europe delegates the portfolio management function and may delegate servicing and trading functions to its affiliates. In particular, the portfolio management function will be delegated to Fisher Investment Europe’s parent company, Fisher Asset Management, LLC, trading as Fisher Investments (“Fisher Investments”), which is based in the USA and is regulated by the US Securities and Exchange Commission (SEC). In addition, client servicing functions may be carried out by Fisher Investment Europe, its affiliate, Fisher Investments Europe Limited, trading as Fisher Investments UK (“Fisher Investments UK”), which is based in the UK and is regulated by the UK Financial Conduct Authority (FCA), or other affiliates, and trading functions may be carried out by Fisher Investments Europe, its affiliate, Fisher Investments Luxembourg, Sàrl (“FIL”), which is based in Luxembourg and is regulated by the Commission de Surveillance du Secteur Financier (CSSF), Fisher Investments, or other affiliates. Fisher Investments Europe may also delegate certain ancillary services to Fisher Investments, Fisher investments UK, or other affiliates.

General


Investing in financial markets involves a risk of loss and there is no guarantee that all or any invested capital will be repaid. Past performance neither guarantees nor reliably indicates future performance. The value of investments and the income from them will fluctuate with world financial markets and international currency exchange rates.

Not all past forecasts were, nor future forecasts may be, as accurate as others. There can be no assurances that investment returns from a particular strategy or allocation will exceed returns from another strategy or allocation.


Top 5 Brokers & Execution Quality (data for calendar year 2018)

Below are the top five execution venues per financial instrument for the previous year for our Fisher Investments Europe clients. Fisher Investments Europe is providing this information on an annual basis to comply with MiFID II regulations.

Broker Execution Score Rank % of Notional Traded (Institutional Client) % of Notional Traded Equity % of Notional Traded Fixed Income % of Notional Traded Mutual Funds % of Notional Traded Derivatives Trade Volume Rank
Goldman Sachs & Co 16 15.3% 15.3% 0.% 0.% 0.% 1
Jefferies & Co 9 13.3% 13.3% 0.% 0.% 0.% 2
Citigroup 12 12.% 12.% 0.% 0.% 0.% 3
UBS Securities 13 10.8% 10.8% 0.% 0.% 0.% 4
JP Morgan Securities 7 10.5% 10.5% 0.% 0.% 0.% 5

*Avg. Execution Score Rank: All executions for each approved broker are measured against three trading benchmarks:

  • Trade Date Open
  • Volume Weighted Average Price (VWAP)
  • Trade Date Close

Differences between average prices and benchmarks are expressed in percentage terms (difference divided by trade value) and are rolled-up by broker into a weighted average percentage difference across each of the three benchmark measures. All 16 approved brokers are ranked across the three different benchmark measures (top-rank meaning the smallest % difference from the benchmark). A weight is applied to each benchmark ranking (Trade Date Open = 70%, VWAP = 15%, Trade Date Close = 15%) and the average ranks are rolled-up into a final “Average Execution Score Rank.”

Example:

Broker X:

  • Trade Date Open Rank: 5
  • Volume Weighted Average Price (VWAP) Rank: 10
  • Trade Date Close Rank: 15
  • Execution Score Rank = (70% * 5) + (15% * 10) + (15% * 15) = 7

Execution quality is reviewed on a weekly basis by the Trading team utilizing Trade Cost Analysis (TCA) software. A summary of the TCA is generated quarterly and reviewed in detail with the Trading Practices Committee. Any outliers are reviewed to determine what factors contributed to the execution results and if the factors were within the traders'/brokers' control.

This site has been approved and is being communicated by Fisher Investments Ireland Limited.