Fitzgerald Brennan Asset Management DAC. Public Disclosures — 2021


FITZGERALD BRENNAN ASSET MANAGEMENT DAC

PUBLIC DISCLOSURES

By administration |February16 2022 | Public Disclosures

1. CLIENT ORDER HANDLING ANNUAL RTS 28 REPORT 2021 (Article 28 MiFID II

Directive)

For the year ended December 31st 2021, the top five stockbroking firms in trading volume terms (descending order), where client orders have been transmitted for execution and by asset class is as follows.

Class of Financial Instrument:

1. Equities a (iii) – Band 1 &2

Top Stockbroking Firms:

1. Cantor Fitzgerald

Proportion of volume traded as a percentage of the total in that class 100%.

Proportion of orders executed as a percentage of the total in that class 100%.

Percentage of passive orders N/A.

Percentage of aggressive orders N/A.

Percentage of directed orders 100%.

The firm is satisfied that it obtained the best possible outcomes in with respect to the  execution of client orders transmitted for execution by the relevant stockbroking firms. Best execution is a multi-factored test, with a requirement on this firm to take all reasonable steps to consistently obtain the best possible result for our clients. The firm assessed the most appropriate venue for the transmission of client orders for execution based on 1. Certainty of execution 2. Client type 3. Costs 4. Order size 5. Price 6. Settlement 7. Speed of execution 8. Any other criteria relevant to the execution of the order.

The firm transmitted client orders to stockbroking firms operating on regulated markets or using multi-lateral trading facilities (MTF). Some client orders may be aggregated, when it is in their best interest to do so. The firm ensured that orders executed on client’s behalf were promptly and accurately recorded and allocated. The firm regularly reviews its best execution policies and procedures.

February 2022