Terms of Dealing
ASIL Partners LLP ("ASIL Partners" or "ASIL") Terms of Dealing
The purpose of this document is to describe the trading relation between you and ASIL (“we” or “us” or the “Firm”). ASIL’s dealings with you are governed by the terms of this document unless expressly agreed otherwise.
Acting as Principal:
ASIL Partners transacts in financial products and investments such as but not limited to Mortgage Backed Securities, CLOs, commodities and currencies. The Firm conducts these activities as Principal, unless expressly agreed otherwise with regard to certain transactions.
On the principal transactions, the Firm acts on its own behalf and interests and does not provide advice. The Firm expects you to conduct your own due diligence and ensure any transactions entered into with us are appropriate based on your circumstances, and independently assess the merits of your entering the transaction.
Acting as Agent:
When acting as your Agent, we shall specify the mode in which you want to deal with us for spread between the price at which we buy and sell and an ASIL mark-up. Unless otherwise specified, we shall include a reasonable mark-up in the price, in accordance with bid/offer spreads in the asset class in line with the prevailing market conditions. The Firm, when acting as Agent, will act solely as agent for the purpose of execution. ASIL will not otherwise act as an agent, advisor, fiduciary or such capacity on your behalf.
Client Categorisation:
Unless otherwise expressly agreed, we treat all counterparties we deal with as an Eligible Counterparty (“ECP”).
ECPs are not treated as clients for the purposes of order execution. Best execution guidelines for orders under Mifid II do not apply to ECPs.
As part of our policy, the Firm does not deal with retail clients.
Not a Fiduciary:
ASIL Partners is not acting in a fiduciary capacity in its dealings with you. In Non-UK and Non- EEA jurisdictions, ASIL Partners will only deal with you if you are a QIB, and do not act as a fiduciary to you.
Conflicts of Interest:
The Firm may choose to Buy/Hold/Sell products that we execute with you and may sell or buy from time to time in the Firm’s sole discretion. Any profit or loss resulting from such activity, in relation to the prices shown to you and the cost of the transactions to us, will accrue solely to ASIL.
All communication from ASIL to you may potentially contain information where our interests may conflict with yours. Such communication includes but is not limited to transactions, indicative quotes, firm quotes, trade ideas, expressions of interest, placement of orders and execution of orders.
Information Handling:
All our trading lines are recorded and such records are kept in accordance with the Firm’s policies.
Pricing:
ASIL Partners principles provide that prices offered shall be reasonable. In addition, pricing offered shall be in accordance with liquidity and availability of such assets in the prevailing market conditions.
Any price that is offered or bid by ASIL shall be the “all-in” price that incorporates mark-ups or costs on top of prices that the Firm traded with other counterparties. Such levels may also differ from counterparty to counterparty. Any such levels, whether firm or indicative, depends on a variety of factors including prevailing market conditions and availably of such assets, and are determined solely at the discretion of ASIL. Unless expressly agreed otherwise, ASIL will offer these levels trading in its capacity as principal, and our interests may differ from yours. It is your responsibility to do your due diligence and establish that the prices of such assets shown are suitable and reasonable depending on your individual circumstances.
ASIL Partners my have a stake with clearing systems through which we handle client orders or trade requests. This could result in profit or benefits that accrue to ASIL. You will not be entitled to a share of any such benefits, economic or otherwise.
ASIL may choose to vary prices by platform in accordance with economic or other considerations, which would result in you potentially receiving different prices on different platforms.
Indicative Terms / Pricing Levels:
Unless explicitly said that it is firm, all prices we disseminate are indicative until confirmed. If a trade is not executed within 15 minutes of this confirmation, prices must be refreshed with one of our Authorised Traders.
Any BWIC levels that are shown to us will be firm for 2 hours after submission. Any such BWIC levels submitted by us are indicative until confirmed.
Order Handling:
When accepting orders from you in the event of expressly agreeing to act as Agent for execution, ASIL will attempt to execute the trade at or near the requested quantity and prices. However, ASIL will not be committed to doing so. Also, this shall not apply to transactions where ASIL is active as principal.
ASIL Partners deals with many counterparties, and could receive multiple requests for the same or similar products it makes markets in. We may also engage in transactions on these assets for our own account or to hedge our exposure. We retain discretion as to how such competing interests will be addressed. We will also be under no obligation to disclose to you that we have our own orders, or other counterparties’ orders in the same assets that relate to your order. Under certain circumstances, this could mean your order would not be completely filled, while another counterparty’s could be.
ASIL may, at its sole discretion, aggregate your orders with our own or other counterparties’ orders as received above, and will allocate proceeds or assets as ASIL considers appropriate. This could sometimes result in better or worse prices than if your order would have been executed on its own, depending on prevailing conditions.
Communications:
Any trade bids/offers or requests from you shall not be deemed received unless confirmed by an authorised ASIL trader. We do not accept orders or trade requests sent through voicemail systems or fax.