Order Transmission and Best Execution Disclosure
How Quorum Capital seeks to act in clients' best interests when transmitting model portfolio orders to third-party platforms for execution.
For discretionary model portfolio orders transmitted to third-party platforms
1. Purpose and scope
This disclosure explains how Quorum Capital Limited seeks to act in clients’ best interests when placing or transmitting orders to third-party entities for execution. Quorum Capital does not normally execute client orders directly on markets. Orders arising from discretionary model portfolio decisions are placed with, or transmitted to, third-party investment platforms, custodians, fund supermarkets or other execution entities for execution.
This disclosure applies to orders generated by Quorum Capital’s discretionary model portfolio service. It is intended for adviser firms and clients who access Quorum Capital portfolios through regulated adviser and platform arrangements.
2. Regulatory basis
When Quorum Capital provides portfolio management or receives and transmits orders, it must act in accordance with the best interests of its clients when placing or transmitting orders to another entity for execution. This disclosure summarises the arrangements used to support that obligation.
3. Instruments covered
Quorum Capital model portfolios typically use platform-available investment instruments, including:
- UK authorised collective investment schemes, including OEICs and authorised unit trusts;
- offshore funds or collective investment schemes where available on relevant platforms;
- exchange-traded funds and exchange-traded commodities, where used within a model portfolio; and
- other platform-available instruments used within an approved model portfolio, where appropriate.
4. Execution factors
When placing or transmitting orders, Quorum Capital considers the following execution factors:
| Execution factor | How it is considered |
|---|---|
| Price | For fund orders, this is typically the relevant valuation point or dealing price applied by the fund/platform. For exchange-traded instruments, price is considered together with total transaction cost. |
| Costs | Platform charges, transaction charges, dealing spreads, fund dealing costs and any other execution-related costs are considered where applicable. |
| Speed | Relevant where delay could disadvantage clients, while recognising that fund orders may be processed at the next valuation point or platform dealing cycle. |
| Likelihood of execution | Important for ensuring portfolio changes and rebalances are implemented reliably across platforms. |
| Likelihood of settlement | Relevant to operational certainty and to reducing the risk of failed trades, rejected orders or settlement delays. |
| Size, nature and other considerations | The size of the rebalance, platform functionality, instrument liquidity, dealing cut-offs, order handling, and any restrictions imposed by the platform or adviser arrangement may be relevant. |
For retail clients, the best possible result will usually be assessed by reference to total consideration, meaning the price of the financial instrument together with the costs related to execution. Other factors may be given greater priority where they are necessary to achieve the best overall outcome, for example where likelihood of execution or settlement is critical.
5. Order transmission entities
Quorum Capital transmits or submits model portfolio instructions through the platforms or execution entities on which the relevant model portfolio is made available. Quorum Capital does not itself act as the execution venue and does not normally execute trades directly. The platform, product provider or execution entity is responsible for the execution, custody, administration, reporting and operational processing of orders in accordance with its own terms, policies and regulatory obligations.
The form of agreement differs by platform. In some cases Quorum has a standalone written transmission agreement. In other cases, the relevant terms of business, platform access agreement or discretionary manager agreement allocates execution and reporting responsibilities to the platform or provider. Quorum keeps evidence of those arrangements on file and reviews them as part of its platform oversight process.
| Platform / provider | Instrument / arrangement type | Execution and transmission position | Agreement / evidence basis |
|---|---|---|---|
| Fundment | Platform-available funds, ETFs, VCTs, investment trusts, closed-ended investment companies and bonds executed on a trading venue where reportable. | Quorum transmits investment orders to Fundment. Fundment is responsible for execution processing and Article 26 / MiFIR transaction reporting for reportable instruments, using information provided by Quorum where required. | Standalone written transmission agreement between Quorum Capital and Fundment. Fundment validates and reports, directly or through an Approved Reporting Mechanism, by the required reporting deadline. |
| Investment Funds Direct Limited / M&G Wealth / Ascentric | Model portfolio instructions and platform-available investments. | Quorum instructs IFDL to purchase or sell investments through the platform. IFDL administers client accounts on an execution-only basis and is responsible for best execution of orders on the platform in accordance with its execution policy. | Platform legal agreement / terms of business. The agreement records the respective DFM and platform roles and IFDL execution responsibility. |
| Fidelity FundsNetwork / Financial Administration Services Limited | Client FundsNetwork accounts and platform-available funds or products. | Quorum is granted access to relevant intermediary client accounts to provide discretionary management services. Fidelity may rely on electronic instructions accepted in good faith as having been given by an authorised person and processes instructions under its FundsNetwork arrangements. | DFM bipartite agreement and FundsNetwork terms of business, including provisions governing appointment of a third-party discretionary manager and platform processing of instructions. |
| Aviva X-Hub / Aviva Wrap UK Limited / Aviva Pension Trustees UK Limited | Model portfolio service available through the Aviva Platform / X-Hub. | Quorum submits model portfolio instructions through the X-Hub. Aviva is responsible for custody, execution, administration, associated reporting and maintaining execution arrangements designed to obtain the best possible result in accordance with FCA rules. | Aviva X-Hub agreement. Aviva has confirmed that a separate bespoke transmission agreement is not necessary or appropriate because the existing X-Hub agreement allocates execution, custody, administration and reporting responsibilities. |
| Utmost / Old Mutual International arrangements | Policy-linked insurance bond / life policy arrangements rather than a standard platform execution arrangement. | The provider owns the assets linked to policyholder policies and places trades in its own name. Quorum does not select or control the execution venue in the same way as for standard platform-transmitted orders. | Provider correspondence confirms that the policyholder owns the policy, while the provider owns the underlying assets and places trades through relevant fund managers or stockbrokers as applicable. |
Website publication note: this table summarises the main platform/provider arrangements currently evidenced by Quorum. It should be reviewed before each publication or annual review cycle to confirm that it remains accurate and complete.
6. Selection and review of platforms and execution entities
Quorum Capital considers the suitability of platforms and execution entities through its due diligence and ongoing oversight arrangements. Relevant factors may include:
- the entity’s regulatory status and permissions;
- the entity’s order execution, order handling and dealing arrangements;
- the contractual basis on which execution, custody, administration and reporting responsibilities are allocated;
- the range of instruments available and the ability to support Quorum Capital model portfolios;
- charges, transaction costs, dealing cut-offs and settlement arrangements;
- operational reliability, error handling, rejected trade rates and settlement performance;
- quality of data, reporting and portfolio administration;
- financial standing, operational resilience, cyber controls and service continuity; and
- any complaints, incidents or recurring adviser feedback relevant to order handling or client outcomes.
7. Monitoring
Quorum Capital reviews its order transmission arrangements at least annually and when a material change occurs. Monitoring may include review of platform execution policies, platform terms or transmission arrangements, dealing incidents, failed or rejected trades, transaction reporting arrangements where relevant, complaints, operational issues, adviser feedback and material changes notified by platforms or providers.
Where Quorum Capital identifies recurring or material issues with an execution entity, it may escalate the matter to the platform, restrict use of the relevant instrument or platform, or consider alternative arrangements where appropriate and available.
8. Aggregation, allocation and model portfolio rebalances
Quorum Capital may implement portfolio changes through model portfolio rebalances. Where orders are placed or transmitted across multiple clients or platforms, Quorum Capital seeks to ensure that orders are handled fairly and consistently. Platform dealing arrangements, cut-offs and settlement mechanics may mean that execution timing and prices differ between platforms or client accounts.
9. Specific instructions and platform constraints
Where an adviser, client mandate, platform or other arrangement imposes a specific instruction or restriction, Quorum Capital may be limited in the steps it can take to achieve the best possible result. Such instructions or constraints may affect the outcome obtained for the client.
10. Conflicts and inducements
Quorum Capital seeks to manage conflicts of interest so that they do not impair its duty to act in clients’ best interests. Quorum Capital does not select platforms or execution entities on the basis of payments, commissions or non-monetary benefits that would conflict with its best execution or order transmission obligations.
11. Review and updates
This disclosure is reviewed at least annually and whenever a material change occurs to Quorum Capital’s order transmission arrangements, platform/provider relationships, instrument universe or regulatory obligations. The supporting evidence pack should retain the applicable platform agreements, terms of business, execution-policy references and transmission or reporting correspondence.
12. Contact
Questions about this disclosure may be sent to Quorum Capital Limited at generalenquiries@quorumcapital.co.uk or by post to Rosedale Studios, Rosedale Road, Richmond, TW9 2SX.
Note: This disclosure summarises Quorum Capital’s order transmission arrangements. It is not a guarantee that the best possible result will be achieved for every individual order, particularly where order handling depends on third-party platform execution arrangements.