Legal
Order handling and execution disclosure
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 handle client orders — from generation through transmission, allocation and record-keeping — if and when a regulated service exists. It is not final, is not in force, and requires legal and compliance approval. No live trading takes place for clients today.
Order generation and validation
Under the intended model, orders would be generated from Black Pool Capital's systematic models within each client's agreed investment guidelines, and would be validated against those guidelines and applicable constraints before being acted on. The definitive generation and validation logic depends on the future service model.
Pre-trade controls
Black Pool Capital intends to apply pre-trade controls designed to check orders against limits and restrictions before transmission, such as guideline, size and eligibility checks. The specific controls would depend on the confirmed operating and provider arrangements.
Broker submission
Validated orders would be transmitted to one or more executing brokers for execution. No executing broker is confirmed.
Aggregation and allocation
Where orders for more than one client are combined for transmission, Black Pool Capital intends to aggregate only on a fair and documented basis and to allocate executions, including partial fills, fairly among the clients concerned. The detailed method depends on the future service model.
Partial fills, cancellations and rejections
Orders may be executed only in part, may be cancelled, or may be rejected by a broker or venue. Black Pool Capital intends to handle such outcomes in accordance with documented procedures and clients' interests. The procedures depend on confirmed execution arrangements.
Corrections and error handling
Where an order or execution error occurs, Black Pool Capital intends to identify, escalate and correct it under a documented process designed to treat affected clients fairly. The detailed error-handling process is not yet established.
Fairness and conflicts
Black Pool Capital intends to handle orders fairly and in the order received where practicable, and to manage conflicts that could affect order handling, including any conflict between clients or between a client and Black Pool Capital, consistently with its conflicts-of-interest policy.
Market disruption and client-specific restrictions
In disrupted or exceptional market conditions, normal order handling may not be possible, and Black Pool Capital would act in the fund's and its investors' interests in the circumstances then prevailing. Black Pool Capital also intends to respect the restrictions of the fund's investment policy.
Audit trail and reconciliation
Black Pool Capital intends to maintain an audit trail of order handling and to reconcile orders, executions and positions against records from brokers and custodians. The systems and cadence for this depend on confirmed provider arrangements.
Missing factual inputs
The following remain undetermined and are required before this document could be finalised: the executing-broker and custody arrangements; the definitive pre-trade controls; the aggregation, allocation and error-handling procedures; and the audit and reconciliation systems. None of these may be assumed.
Status: draft placeholder. Last updated: not yet published.