Trading Order Execution Policy

 

MFP Trading Ltd. (“MFP”) offers its clients an anonymous ECN trading platform (“Platform”) from which to execute transactions in spot-settled foreign exchange and certain spot settled precious metal products. The Platform operates two separate and distinct matching engines located in New York, and London (located at data centers NY4, and LD4). Each matching engine emits its own market data, trades, and midpoint values. MFP acts as Agent for all activity on the platform and is never principal to any transaction.

The Platform does not permit transactions in “swaps,” as defined by the Commodity Futures Trading Commission (“CFTC”), derivatives contracts, or any other capital markets products as defined under the Securities and Futures Act 2006, as may be amended, or updated from time to time (“SFA”). References to “Spot FX” shall mean and include spot trading in precious metals, unless otherwise required by the context. Users must have the ability to effect physical delivery with respect to transactions occurring via the Platform; the transactions occurring on the Platform are not rolled as a matter of course; and any netting will only be done in accordance with a pre-negotiated netting agreement. MFP is not responsible for compliance by Users with regulatory obligations applicable to swap dealers or otherwise imposed by rules of the CFTC. Participants must secure a credit line with one or more partnered central counterparties.

MFP has the ability to create custom liquidity pools by specific requirements, for example: order size requirements, specific book tiering, order timing constraints, order allocations, trade netting, algorithmic execution and fill rate guarantees by simple aggregation, cross-matching and hedging methods. In this capacity MFP is acting as an Agent between clients and providers and therefore:

MFP will always work with the counterparties involved to make sure the best setup is achieved and to protect everyone’s interest is as much as possible.

MFP will act as neutral as possible with regards to market risk taken, market impact and information leakage.

MFP will never analyze or use profile information, market data, order and or trading data from clients or providers for its own benefit.

MFP white labels technology from a third party but retains full control over all pricing and participants in their dedicated environments.

MFP will provide oversight and monitoring of their systems to detect actual or attempted market manipulation and respond accordingly.

MFP’s bespoke liquidity management team will ensure that there is proper governance overlooking the behavior of all participants and will work for all participants to create the best pool of liquidity on an individual client level.

MFP can either charge its clients by collecting a spread or by sending an invoice.

 

2. MFP ECN

2.1 General

2.1.2 Access to MFP

A client can submit orders to MFP using the GUI trading client or via API. For more information, please contact our Sales and Liquidity management team at [email protected]

In an emergency, a client may contact the team with a request to place a voice order, however it is expected that clients not rely solely on MFP as their only access to the market. Voice orders will be entered into the ECN and processed in the order received. Any prices quoted over the phone during this process are indicative. Once the order has been worked in the system the team will then confirm the final rate and amount of any resulting trade. These details will be transmitted to the client using a pre- defined email on file.

2.1.3 Trading Hours

MFP opens on both locations Sunday 5 PM EST and closes Friday 5 PM EST. The FIX connections will be unavailable from Monday to Thursday 5 PM EST – 5:05 PM EST. Trading hours are not affected by holidays however the pricing available during holidays may be limited.

 

2.1.4 Support

The MFP Support Team can be reached at [email protected]. For urgent matters they can be reached during trading hours at +44 203 769 9884.

 

2.1.5 Out-of-line situations failures

In case of out-of-line situations or failures, MFP might temporarily shut down its pricing or might be turned off completely to avoid any risk for its clients and LPs. MFP is monitored closely during trading hours and out-of-line situations will be handled immediately by either MFP itself or by qualified MFP Support Team members. This might result in pausing the supply of pricing or temporary shutdown of one or more MFP components. In case of emergency, a disaster recovery plan is executed to ensure that all MFP components and services will be restored as soon as possible. For urgent issues, the MFP Support Team can be reached 24 7 by phone. Other issues will be handled during UTC office hours.

 

2.2 Platform functionality

2.2.1 Order book

An order book consists of all received quotes and orders for a symbol. Both sides of the order book are sorted by best price (highest bid lowest offer), highest quantity and newest entry.

 

2.2.2 Quotes

Every incoming quote is matched against all resting orders on the opposite side of the order book. LP quotes are not matched to other LP quotes.

 

2.2.3 Orders

Orders will be processed immediately after receipt by MFP, no holding times are applied. Each order will be validated and verified upon authorization, completeness, and correctness. Orders that do not pass the validation or verification will be rejected. If an order is accepted, the client receives a confirmation of the order receipt.

 

Incoming orders are matched against all quotes. A match with a resting order will be executed immediately. A match with a quote will result in a Trade Request to an LP with last look.

 

2.2.4 Last Look

Allowed LPs will perform a last look on a Trade Request, i.e. accept, reject or cancel an order without any reason.

 

2.2.5 Client Tags

MFP will allocate an official account ID to any GUI or API user. When a client trades either via a GUI or API an anonymous taker ID is also generated and sent to the executing LP within the Execution Report. This anonymous taker ID can be made up of multiple digits and or characters – Anonymous taker IDs are provided given that the LP can consume the specific tag that we send it in.

Only the account username will be visible in the New Order Single, meaning that the anonymous tag is only provided to an LP once a transaction has been executed.

2.2.6 Order Execution

An order that awaits the result of one or more trade request is deemed “working” and cannot be altered or cancelled. After the last trade request result has been received, the order becomes filled, partially filled, or not filled at all. Depending on the TimeInForce (TIF) and TimeToLive (TTL), an order with a remaining quantity will be cancelled or will become a resting order in the order book.

An order that allows partial fills may receive an execution report for each fill on the order. Every order will receive a final execution report which either cancels the order completely, fills a partial quantity, or fills the order completely.

 

2.2.7 Time outs

A client order that awaits the result of one or more trade request will be held against the time out rules. If an LP is not obeying the time out rules agreed upon, any fill will not be accepted by MFP. If the client order exceeds the time out period, the remaining quantity will be canceled. MFP supports custom time out rules. Time out rules should be communicated to [email protected] during account onboarding.

 

2.2.8 Transaction Disputes Off-market deals

Although MFP has taken the highest measures to minimize the risk of off-market deals, off market deals may take place. Please contact MFP as soon as possible for any off-market deals so the MFP can renegotiate the price on the transaction to within market boundaries. MFP’s support team is available at [email protected] MFP cannot be held responsible for off-market deals that are not flagged prior to settlement.

 

2.2.09 Market data

MFP aggregates market data from its LPs and resting client orders to an order book per symbol. MFP supplies order books as market data snapshots to its clients based on subscription request, availability, and applicability, in real time or subject to a refresh rate configured per client. Both sides of the order book are sorted by best price (highest bid lowest offer), highest quantity and newest entry. Clients will only receive market data from LPs and resting orders from clients they can trade with. MFP reserves the right to stop taking market data from its LPs and or stop supplying tradeable snapshots to clients any time.

 

2.2.10 Quality of Market Data

MFP continuously monitors the received market data from its LPs. To protect its clients and LPs, MFP will take out market data that is not complying to quality rules defined by MFP, e.g. market data resulting in inverted or crossed books or market data with a bigger tick size than defined by the market. These quality rules are regularly reviewed and are subject to change.

 

2.2.11 Credit Usage Monitoring

Each order will be subject to a credit usage check. Each counterparty is configured with a credit limit. This credit limit is applied to all locations where the counterparty is active, i.e. all trades done on all MFP locations together count towards the credit usage. The credit usage is continuously monitored over all locations and each order will be held against the configured credit limit. If the credit limit would be exceeded when the order would be filled, the order will be rejected. The counterparty and or its PB will be informed when the credit usage reaches 80% of the configured credit limit. Each order resulting in a breach of the credit limit will be rejected. If an LP breaches its credit limit, the market data of that LP will not be processed and published anymore, until the credit limit is not breached anymore.

 

2.3 Dealing rules

2.3.1 Pre-hedging (during the last-look window)

MFP does not allow liquidity providers to pre-hedge during the last-look window. Whenever MFP finds evidence that this is happening all live connections with the LP will be switched off and MFP engages to find ways to re-establish a relationship without harming other MFP clients.

2.3.2 Sweeping

MFP monitors the trading environment to protect LPs from clients that are either sweeping a complete book or from continuously dripping orders to an LP. MFP can prohibit LPs from being swept or MFP can prohibit clients from sweeping, based on a configurable trigger. The ECN will wait for an answer from a LP before sending another order i.e. If an order attempt is in'flight' vs an LP, the ECN will not target the same LP again until it has received a response from the initial order request.

Unless sweeping is prohibited, each order will be swept across the book, taking the matching rules into account. For example, if the sorted order book contains 3 layers, 1M, 2M and 3M, and a 3M orders is received and matches all three layers, it will hit the quotes in the sorted order, i.e. hit the 1M and 2M quotes.

If MFP detect trading behavior to be different from expected, or initially shared, MFP can reconfigure liquidity accordingly. Including how Market Data is distributed and how the execution algorithm works orders on the backend i.e. from FA to Sweep and vise versa. MFP will do this to ensure our LPs are protected and the given streams are being purposed and used as expected.

2.3.3 Re-distribution of market data

Redistribution of market data may affect the quality of the pricing to which you have access. Some of our LPs have strict policies relating to data leakage and will either not be shown to specific tags or may be removed from certain tags if MFP finds that redistribution is taking place.

 

2.3.4 Client obligations

A client should not share or leak information that could damage MFP, MFP staff or other MFP clients or LPs.

A client should avoid conflicts of interest when trading with MFP.

Market data that is sent to a client is solely intended for trading purposes of the client.

2.3.5 MFP obligations

MFP will not share or leak information to MFP clients, LPs, or other related parties.

MFP will avoid any conflict of interest; it will not use information resulting from MFP, like ordering behavior, pricing behavior, fill or reject ratio’s etc.

MFP saves audit trails of orders and trades.

MFP monitors system behavior and system wellness.

MFP takes the highest measures to ensure a correct, fast, and safe working ECN.

In case of issues or emergency, MFP will protect its clients and LPs by taking security measures that will mitigate the risks for its clients and LPs.

A BCP or disaster recovery plan is present and regularly tested.

3. Global Code of Conduct

On December 6, 2022, MFP signed the Statement of Commitment whereby it supports and commits to the FX Global Code of Conduct. The FX Global Code is a set of global principles of good practices to promote the integrity and effective functioning of the wholesale FX market. MFP will actively promote and contribute towards a robust, fair, liquid, and open transparent FX market with a robust and fast infrastructure, competitive pricing, and innovative technology.

 

4. MFP Partners

MFP is using two Prime Brokers for its service to provide liquidity towards clients. Since 2017 NatWest Markets has been the preferred Prime Broker for MFP. During 2022 Standard Chartered has been added as secondary prime broker to mitigate operational risks and remain competitive towards all clients.

 

5. Definitions

ECN Electronic Communications Network. The ECN provides an electronic system for buyers and sellers to come together for the purpose of executing trades. It does this by providing access to information regarding orders being entered, and by facilitating the execution of these orders. The network is designed to match buy and sell orders currently present in the exchange. When specific order information is not available, it provides prices reflecting the highest bid and lowest ask listed on the open market.

Client Trading client

Liquidity Provider (LP) Supplier of market data

Counterparty Client or LP

Symbol Currency pair

Order Client request to buy or sell a symbol

Quote Bid or offer from an LP

Market Data Collection of quotes

Order book Collection of quotes and orders for one symbol

Time To Live (TTL) User setting that specifies the default time an order remains in effect within MFP. If there is no immediate match between 2 opposite orders market quotes, TTL can extend the duration of the order until a pre-set end time to increase the chance of an offsetting transaction.

Order types

The MFP platform supports the following order types. For a detailed explanation, please refer to the latest version of the MFP FIX specification.

Market A market order is an order to buy or sell at the current market price.

Limit A limit order is an order to buy or sell at a specific price or better.

Market Limited: A Market Order with customer defined maximum slippage

Order timing

An IOC or AON order with a specified Duration will be canceled after the specified TTL, if not filled. This makes it possible to enter the matching process multiple times within the TTL as aggressing order, in order to find a match. IOC and AON orders without TTL will enter the matching process only once.

Day Order expires at the end of the trading sessions, i.e. 5:00 PM ET. This includes all NZD-related orders, for which the trading day roll-over has already taken place.

Good Till Cancel (GTC) Order never expires, unless canceled by the client.

Immediate Or Cancel (IOC) Order will be immediately filled for as much as possible up to the entire order quantity, any remainder will be canceled.

All of None (AON) Order will be immediately filled for the full quantity of the order or canceled by the system if there is no match. Partial fills are not possible.