Legal
Best execution policy
Draft — not yet in force — requires legal and compliance approval
This document is a placeholder drafted for internal review. It is not legal advice, is not final, and does not yet govern any relationship with Black Pool Capital. Final policies will be published before any service becomes available.
Purpose and status
This document is a framework draft prepared for internal review. It describes how Black Pool Capital intends to seek the best possible result for clients when transmitting or placing orders for execution, if and when a regulated service exists. It is not final, is not in force, and requires legal and compliance approval. No orders are transmitted for clients today.
Intended execution objective
Black Pool Capital intends to take sufficient steps to obtain the best possible result for clients on a consistent basis, taking account of the relevant execution factors and of the characteristics of the client, the order, the instruments and the available execution arrangements.
Execution factors
Black Pool Capital intends to consider factors including price, the costs of execution, the speed and likelihood of execution and settlement, the size and nature of the order, and any other consideration relevant to executing it. The relative importance of these factors would depend on the circumstances of each order and on the client's classification.
Reliance on future brokers
Under the intended model, Black Pool Capital would generally transmit orders to one or more executing brokers rather than executing on a venue itself, and would rely in part on those brokers' own execution arrangements. No executing broker is confirmed, and no execution arrangement is in place.
Execution venues
The venues on which orders would ultimately be executed depend on the arrangements of future executing brokers and on the instruments concerned. No execution venues are confirmed, and none is endorsed here.
Client-specific instructions
Where a client gives a specific instruction about an order or its execution, Black Pool Capital intends to follow that instruction to the extent it does so, which may prevent Black Pool Capital from taking the steps described here to obtain the best possible result for the aspects covered by the instruction.
Order aggregation and allocation
Where orders for more than one client are combined, Black Pool Capital intends to do so only on a fair and documented basis and to allocate the results, including partial fills, fairly among the clients concerned. The detailed method depends on the future service model.
Exceptional market conditions
In disrupted, illiquid or otherwise exceptional market conditions — including outages affecting a broker or venue — achieving the usual execution result may not be possible, and Black Pool Capital's priority would be to act in clients' interests in the circumstances then prevailing.
Monitoring, review and missing inputs
Black Pool Capital intends to monitor execution quality and to review this policy and its execution arrangements periodically and when a material change occurs. Because no brokers, venues or execution arrangements are confirmed, the monitoring approach and review cadence are not yet fixed.
Status: draft placeholder. Last updated: not yet published.