Order Handling, Allocation and Execution Policy

Dear client, please read this policy carefully as it indicates the business model that we, Coverdeal Holdings Ltd. follow in our business relationship with our clients.

About our Company

Coverdeal Holdings Ltd operates as a European Union CFD Online Trading Broker.

  • Coverdeal Holdings Ltd (hereinafter “the Company”) is incorporated in Cyprus under Registration Number HE 303127 through the Department of Registrar of Companies and Official Receiver (http://www.mcit.gov.cy).
  • Coverdeal Holdings Ltd (with commercial name “Globtrex.com”) is a Cyprus Investment Firm authorised and regulated by the Cyprus Securities and Exchange Commission (‘’CySEC’’) under License Number 231/14. Details about the extent of our regulation by CySEC are available at (http://www.cysec.gov.cy/en-GB/entities/investment-firms/cypriot/37692/)

We shall refer to Coverdeal Holdings Ltd as “we”, “our” or “us” and to our clients or potential clients as “you”, “your” or “yours” throughout the rest of this Order Handling, Allocation and Execution Policy.

As a regulated entity in the European Union, we comply with the regulatory requirements of CySEC for Cypriot Investment Firms, including the Investment Services and Activities and Regulated Markets Law of 2007 of the Republic of Cyprus 87 (I)/2017 and the Markets in Financial Instruments Directive (“MiFID II”) of the European Union.In regards to the offering of cryptocurrency CFDs as the underlying asset, the Company has been granted with the Commission’s exceptional approval, as per the provisions of the Section 6(9)(b) of the Law.

MiFID requires us to establish and implement and Order Handling, Allocation and Execution Policy and to provide clients with a copy of that policy detailing the handling, allocation and execution arrangements and sufficient steps that we employ and take to comply with our duty to give our clients best execution.

At the same time this policy is issued pursuant to, and is in compliance with, that Directive (“MiFID II”) and the Rules of CySEC, which is responsible for implementing MiFID in the Republic of Cyprus and regulating the activities of Coverdeal Holdings Ltd.

In our business relationship with clients, we have a duty to act honestly, fairly and professionally, and to provide information that is fair, clear and not misleading, taking into account the Customers Best Interest. In relation to Order Handling, Allocation and Execution, we are required to obtain the best possible result when executing client orders or when placing orders with, or transmitting orders to, other entities to execute.

The definition of “best execution” varies and is not an easy question to answer, a range of execution parameters must be taken into account to determine their relative importance based on the market participants we serve and the importance they place on each factor, the orders we receive, the markets in which we operate and the financial products we support. For retail clients we must consider all parameters, specially fair price and costs (implicit, explicit external and explicit internal) which are part of the assessment known as “Total Consideration”, we must additionally consider, including but not limiting ourselves to, speed of execution, certainty of execution, access to execution, likelihood of settlement, size, nature and timing of the transactions, clearing robustness, credit relationship, “captive trades” or any other consideration relevant to the client and the execution of the order. In an applicable sense, best interest in execution can be seen as a client trade request getting filled near instantaneously at or better terms than those requested, based on the prevailing liquidity at the time and order flow of the executing institution/venue and within consideration of the credit (risk) of the participants and their access constraints and tenure of the contracts.

Summary of our Policy

This Order Handling, Allocation and Execution Policy will state:

  1. Our Execution Venue
  2. Our execution approach for handling and allocating orders from origination to execution
  3. Factors that influence our execution, and
  4. Our monitoring and review of the best execution obligation

Coverdeal Holdings Ltd is in a particular regulatory position to provide its clients with best execution in so far as we are authorized to provide (only) the investment services of:

  • Reception and Transmission of Orders in relation to one or more Financial Instruments, and
  • Execution of Orders on Behalf of Clients

The Reception and Transmission of Orders (RTO) consists for services in receiving orders from clients to negotiate financial instruments and transmit such orders to a service provider so that the orders could be executed on the markets.

The Execution of Orders (Execution) consists for services in acting on behalf of a client to conclude transactions on financial instruments in compliance with the orders received from the client. Acting on behalf of the client, our services lead the transaction process until the end (negotiation and conclusion).

Please note that our services cannot offer Investment Advice.

Our single Execution/Dealer Venue is Safecap Investments Ltd.

Your orders will be executed exclusively, and without exception on Safecap Investments Ltd, a Cyprus Investment Firm authorised and regulated by the Cyprus Securities and Exchange Commission (‘’CySEC’’) under License Number 092/08.

Our Execution Venue therefore has rigorous procedures in place to deliver Best Execution.

Notwithstanding we have ongoing and independent processes in place for monitoring the quality of execution obtained on your behalf from our sole Execution Venue, since as a retail client you legitimately rely on us to protect your interests in relation to the pricing and other factors of a transaction executed on your behalf at any Execution Venue.

This order handling, allocation and execution policy, as amended from time to time, together with the Company’s other legal documents form our agreement with you. This English version of the policy prevails in the event of any inconsistencies or ambiguities over any translations into other languages that might be provided for referential purposes only.

By commencing trading with us, you have consented to the contents of the current version of this order handling, allocation and execution policy.

If you believe that your order has not been handled, allocated or executed in line with this policy, then you should contact our Reception, Transmission and Execution of Orders Department at the soonest.

RTO & Execution Department

Email: rte@globtrex.com

Tel: +357 25 635 040

Fax: + 357 25 635 040

Scope and Obligation of our Policy

  • 1.1. We have an obligation to implement procedures and arrangements which provide for the prompt, fair and expeditious execution of client orders, relative to other orders or our own interests.
  • 1.2. In this Order Handling, Allocation and Execution Policy we will be carrying out an order if we:
    • 1.2.1. Execute orders on behalf of clients;
    • 1.2.2. Transmit orders to other entities for execution when providing the service of reception and transmission of orders.
  • 2.1 We are required to ensure that any orders executed on behalf of our clients are promptly and accurately recorded and allocated.
  • 2.2 We will carry out otherwise comparable orders sequentially and promptly unless the characteristics of the order or prevailing market conditions make this impracticable.
  • 2.3 We will inform our retail clients about any material difficulty relevant to the proper carrying out of orders promptly upon becoming aware of such a difficulty.
  • 3.1 If we aggregate a client order with one or more orders, we will allocate the related trades in accordance with this Order Handling, Allocation and Execution Policy. See our Conflict of Interest Policy.
  • 3.2 We place orders on a first come first served basis. The volume and price of an order does not determine allocation of the aggregated order and we will by default not partially execute any order.
  • 3.3 If an error is identified in an allocation, a re-allocation may be made for an aggregated order. In such cases, a record of the reason for and the basis of the reallocation must be carefully documented, and the re-allocation will be completed within one (1) business day of the identification of the error.
  • 3.4 Allocation records for aggregated transactions must include:
    • 3.4.1 The time and date of the allocation;
    • 3.4.2 The relevant product and underlying asset;
    • 3.4.3 The client’s identity and execution venue;
    • 3.4.4 The amount allocated to each client and counterparty involved.
    • 3.4.5 Records relating to aggregated orders must be retained for a period of at least five (5) years from the date of allocation, or re-allocation, as the case might be.

This policy will apply to you if we have categorised you, in accordance with MiFID, as a Retail or Professional or if you are an otherwise categorized client and you have asked for and been assured that we will give you best execution.

Our best execution obligation applies to the following financial instrument and products currently being offered by Coverdeal Holdings Ltd:

  • CFD Equities
  • CFD Indices
  • CFD Commodities
  • CFD Forex
  • CFD Fixed Income
  • CFD Cryptocurrencies

We offer EXECUTION ONLY trading to our clients. We will execute all of our clients’ orders as “Agents”, “Matched Principal” or “Riskless Principal” to the trade. We facilitate each order you place with us by placing an identical order (our Back to Back Order) on our execution/dealer venue or counterparty. Upon our Back to Back Order being matched or filled in whole (see Fill or Kill), we shall open or close a trade on your account (“Back to Back Trade) at the same or marked-up price and in the same size as our Back to Back Order. This means we act as a “Riskless Principal” to every trade opened or closed in your account.

We currently do not execute client orders through any other Execution Venue or counterparty. We therefore place reliance on Safecap Investments Ltd as our single Dealer Venue, though, in accordance with regulatory requirements, we remain solely responsible to our clients for taking all reasonable steps to obtain the best possible result for them.

For this reason, Coverdeal Holdings Ltd requires from our Dealer Venue, through a service agreement, to implement processes and procedures to evidence that, as our single Execution Venue, it will deliver Best Execution and so enable us to meet our Best Execution obligation to our clients. These process and procedures include:

  1. Independent monitoring by Coverdeal Holdings Ltd of the trade execution quality achieved by our Execution Venue in relation to our clients’ orders across MiFID II qualifying products for which Safecap Investments Ltd acts as our single Dealer Venue.
  2. The provision by our Execution Venue of in-house and third party monitoring data to Coverdeal Holdings Ltd, for our independent review.
  3. Coverdeal Holdings Ltd scrutiny of evidence of the regular and systematic review of the Execution Venues that our Dealer Venue uses to meet its own Best Execution obligations since we act as ‘Agents’ and our clients’ orders are using those Venues.
  4. Our direct periodic review of the quality of our Dealer Venue’s execution measured against that of other comparable Venues.

As your order is for an Over-the-Counter (“OTC”) transaction and we act as an “Riskless Principal”, your order is routed to Safecap Investments Ltd as the sole Execution Venue and as a Dealer Venue it will trade against its own account and in turn route its own orders to other Execution Venues.

Warning: We execute your order outside a Regulated Market (“RM”) or Multilateral Trading Facility (“MTF”), such transactions may expose you to greater risks than transactions executed on RM or MTF, so by entering into a business agreement with us you have consented to this policy. See our Risk Disclaimer Policy.

Our Execution Approach

In order to meet our best execution obligation, we and our execution venue take into account the following criteria for determining the relative importance of the execution factors.

  • The characteristics of the client, including whether you are a retail or professional client. This policy does NOT apply to Eligible Counterparties;
  • The characteristic of the client order;
  • The characteristics of the OTC financial instruments that are subject to the order;
  • The characteristic of the execution venue to which the order is directed;
  • The prevailing level of liquidity at the time of execution;

Decisions on Order Handling, Allocation and Execution are primarily based on the following execution parameters which are taken into consideration in determining the best possible outcome when executing an order for a client:

Speed, Certainty and Access to Execution

We attach a HIGH relative importance to Speed, Certainty and Access to Execution.

Due to the levels of volatility affecting prices, we seek to provide client orders with the fastest execution reasonably possible, taking into account any conditions applying to the client’s order. Automatic delays are the standard and may occur since we do not support a manual request for quote. See Dealing on Quotes.

We are not under any obligation to accept an order from a client, and the times at which you are able to submit orders are restricted, furthermore in order to provide protection against any potential adverse consequences of erroneous orders on our platforms we will reject any orders that lie outside of a defined range. These ranges are though necessarily changing due to the liquidity and volatile nature of financial markets, under conditions due not only to news announcements, economic events, market openings/closings, and rapid price movement where to such an extent that under the rules of the relevant exchange where the underlying products are traded and prices are made, trading is suspended and restricted. See Ranking of Execution Factors and MT4 Execution.

The use of wireless connection or dial-up connection or any other form of unstable connection at the Client’s end, may result in poor or interrupted connectivity or lack of signal strength causing delays in the transmission of data between the client and us, when using the firms electronic trading platform.

We rely on our Dealer Venue for liquidity, therefore the execution on a ‘back to back’ basis will depend on the pricing and available liquidity of our Execution Venue.

Price Information and Improvement (Implicit Cost)

We attach a HIGH relative importance to Price Information and Improvement, as together with other costs, these are the parameters that for retail clients take precedence over all other factors when assessing Best Execution.

The price of our financial instrument CFD (“Contract for Difference”) is calculated by reference to the prices of the relevant underlying products, as we obtain them from our Dealer Venue. We will update the prices as frequently as the limitations of technology and communications links allow.

Our Dealer Venue’s prices and its trading hours, and consequently our prices and trading hours which mirror those of our Execution Venue, may differ from those on other Regulated Markets, Multilateral Trading Facilities, Systematic Internalizers or other entities that perform similar functions.

An order placed with us for a specific size will NOT result in a number of trades being executed to fill that order in part, and will only fill in whole. See MT5 Execution and Fill or Kill.

Our Execution Venue will fill orders at Market Price, therefore at market orders and contingent stop loss orders the price you receive at execution will be the best price available at the time the order is executed in whole on our Execution Venue. This could be better or worse than the price on our Execution Venue at the time your order is placed. See Slippage.

In the case of a limit order and contingent profit target orders the price you receive at execution will be the price in your instruction or better. See Slippage.

You must acknowledge that there are several factors as market data latency, speed of your internet connection and high market volatility, that might lead to price slippage.

At all times, Coverdeal Holdings Ltd might use price benchmarks as they are useful in monitoring best execution.

Consideration of Explicit (Explicit External and Explicit Internal) Costs

We attach a HIGH relative importance to Explicit Costs, as controlling them involves additional requirements.

As mentioned before best execution for retail clients’ orders is assessed on the basis of “Total Consideration” which is the sum of price and cost incurred by the clients, this is why we separately identify the explicit internal and external cost of execution for retail clients’ orders.

  • Explicit external costs: We might pass to you a commission, financing fee, currency exchange fee, tax or any other explicit external cost either based or not on prevailing market interest rates in our role of intermediaries to a transaction. See Rollover and Swaps charges.
  • Explicit internal costs: Our execution venue might charge a commission or spread for completing a transaction.

Costs can be found on the company’s website at https://globtrex.com

We can omit our own fees and charges from the assessment of best execution as firms need NOT to reduce its commission to the lowest level in the market in order to deliver best execution to any client including retail clients.

Financial charges or adjustments may apply to your trades. If applicable, these charges or adjustments will result in a debit or credit being made to your account at the time the charge or adjustment becomes effective. This will usually occur whilst the affected trade(s) is open on your account but may occur after that trade(s) has been closed. See Actions for Account Adjustment Policies at globtrex.com

In order to clearly demonstrate to our clients, the difference between price and any external cost incurred, the latter cannot be incorporated into price but instead charged explicitly to the client account. For this purpose, a transparent markup or markdown can be added.

Size and Quantity Available to Trade

We attach a HIGH relative importance to Size and Quantity available to trade.

Our Dealer Venue provides us with accommodative liquidity and potential for execution of relatively large trades in the standard of our retail clients, however as our only Execution Venue there are no opportunities for clients’ orders to benefit from order-size commitments. See Order-Driven Markets.

We reserve the right to place a cap on the minimum and maximum sizes of positions you may hold in an instrument and/or a trade at any one time, in spite of, we will make every effort to fill your whole order at the best available price. Any opening order you place can be subject to these restrictions, and the firm will undertake all possible efforts to notify clients accordingly. Minimum and maximum position sizes might be set for each instrument and may vary depending of the current market conditions. See MT5 Execution for position sizes as they apply from time to time.

Likelihood of Settlement

We attach a HIGH relative importance to likelihood of Settlement.

We will proceed to an STP (“Straight-through-Processing”) settlement in our platforms of a transaction upon execution of such transaction with our Execution Venue.

Overall Execution Quality

When determining execution for an order, we have performed due diligence on our Execution Venue to assess compliance of Best Execution to secure our clients prompt, sequential, reliable and quality result in execution.

When we will execute an order on behalf of a retail client the best possible result is determined first on the basis of total consideration (fair price and costs paid by the client) and then we will prioritise speed of execution, likelihood of execution, settlement, size, nature of the order and any other transaction risk, predominantly in that sequence, unless the underlying product implies different, if they are instrumental in delivering the best possible result in terms of total consideration and quality of execution for our client, as this may be the case in OTC (Over-the Counter) markets.

Our Hierarchy of Execution Parameters

The relative ranking of the different execution parameters will be dependent upon the nature of the underlying product traded, the liquidity of the relevant market and the time of the trade. The ranking depends on where the underlying product is traded: Exchange versus OTC market.

CFD Equities

Safecap Investment Ltd, our Execution Venue will be acting as dealer on quotes. See Dealing on Quotes. The ranking of execution parameters for CFD Equities are:

  1. Price and Cost
  2. Order size
  3. Speed and Likelihood of Execution

Relevant derivate venues for equities pricing benchmark offered in our platform:

UK Equities: LSE

Other European Member States Listed Equities: Deutsche Bourse, Borsa Italiana, etc.

Swiss Equities: SIX Swiss Exchange

Canadian Listed Equities: Toronto Stock Exchange and Vancouver Stock Exchange

US Listed Securities: NYSE, American Stock Exchange and NASDAQ

CFD Indices

CFD Indices prices are our Execution Venue’s proprietary prices, which are derived from the relevant underlying Index price and exchange, taking into account the cost incurred. Safecap Investment Ltd will be acting as dealer on quotes. The ranking of execution parameters for CFD Indices are:

  1. Price and Cost
  2. Order size
  3. Speed of Execution

Relevant derivate venues for indices pricing benchmark offered in our platform:

FTSE 100: ICE Futures Europe

DAX 30: Eurex Exchange

Euro STOXX 50: Eurex Exchange

S&P 500: CME Globex

DOW 30: CME Globex

NASDAQ100: CME Globex

Nikkei 225: CME Globex

ASX SPI 200: Sydney Futures Exchange

Hang Seng Index: Hong Kong Futures Exchange

FTSE MIB: Borsa Italiana

IBEX 35: Meff Renta Variable

Swiss Market Index: Eurex Exchange

CFD Commodities

CFD Commodities prices are our Execution Venue’s proprietary prices, and generally will track that of the relevant underlying exchange traded market. Because there is only one exchange on which to trade the product that underlies these derivatives, we will consider our Dealer Venue “accurate” when it is in line with the underlying future. There is no opportunity to “shop around” for prices in these commodities markets, due to the fact of a unique exchange. Safecap Investment Ltd will be acting as dealer on quotes. The ranking of execution parameters for CFD Forex are:

  1. Price and Cost
  2. Order size
  3. Speed of Execution

Relevant derivate venues for commodities pricing benchmark offered in our platform:

Brent Oil Contracts: ICE Futures Europe

WTI Oil Contracts: CME NYMEX Division

Natural Gas: CME NYMEX Division

Gold Spot: OTC Market (Interbank)

Silver Spot: OTC Market (Interbank)

Palladium Spot: OTC Market (Interbank)

Platinum Spot: OTC Market (Interbank)

CFD Forex

Our Execution Venue sources a number of quotes from their liquidity providers to construct their prices for Currency pairs. As such the price we offer will be consider our “Best” and will automatically update to reflect the best price available at the time of trade for your order. We might monitor the prices used by our Dealer Venue to ensure that the price we show is in line with that stated methodology. Safecap Investment Ltd will be acting as dealer on quotes. The ranking of execution parameters for CFD Commodities are:

  1. Price and Cost
  2. Order size
  3. Speed of Execution

Relevant derivate venues for currency pricing benchmark offered in our platform:

Currency Pairs: OTC Market (Interbank)

CFD Fixed Income

Pricing and execution in the Fixed Income Markets can be a slow process. Our execution Venue will offer a bid/offer price equal or similar to that shown in any attainable fixed income spot/future market (this includes public exchanges and OTC markets). Safecap Investment Ltd will be acting as dealer on quotes. The ranking of execution parameters for CFD Fixed Income are:

  1. Price and Cost
  2. Speed and Likelihood of Execution
  3. Order size and type of product

Relevant derivate venues for fixed income pricing benchmark offered in our platform:

Euro Bund Future: Eurex Exchange

US Treasuries Futures: CME CBOT Division

UK Gilt Future: ICE Futures Europe

Japanese Bond Future: Japan Exchange Group Osaka Division

CFD Cryptocurrency

Note that when trading CFDs where the underlying asset is a Cryptocurrency, you should be aware that: Cryptocurrencies are traded on non-regulated decentralized digital exchanges. This means that the price formation and price movements of the Cryptocurrencies depend solely on the internal rules of the particular digital exchange, which may be subject to change at any point in time and without notice. In addition, such digital exchanges may introduce trading suspensions or take other actions that may result in suspension or cessation of trading on such exchanges or the price and market data feed becoming unavailable to us. The above factors could result in material adverse effect on your open positions, including the loss of all of your invested amounts.

We ensure to derive our market and pricing data from reputable digital decentralized exchanges the Cryptocurrencies are traded on.

As such the price we offer will be consider our “Best” and will automatically update to reflect the best price available at the time of trade for your order. We might monitor the prices used by our Dealer Venue to ensure that the price we show is in line with that stated methodology. Safecap Investment Ltd will be acting as dealer on quotes. The ranking of execution parameters for CFD Bitcoin are:

  1. Price and Cost
  2. Order Size
  3. Speed of Execution

Specific Instructions

Upon acceptance of a client order and when there is no specific client instruction regarding the execution method, we will execute the order in accordance with this policy. When, however, there is a specific instruction from or on behalf of a client, we will, to the extent possible, execute the order in accordance with the specific instruction although some markets may prevent following certain part of the instruction.

Warning: In certain cases, specific instructions from you, may prevent us from taking the steps that we have designed and implemented in this execution policy to obtain the best result for those orders in respect of the elements covered by your instructions.

If we execute an order in accordance with a client’s specific instruction, as is the case with limit orders, we will have complied with our obligation to Best Execution. To the extent that your instructions only cover certain aspects of the order, or they are incomplete, as in the case of market orders, this Policy will be followed for those parts or aspects of the order not covered by your instructions.

Types of Orders

Given the risks that arise when trading in volatile markets, clients may want to consider using different types of orders to limit risk and manage investment strategies. See our Risk Disclaimer and MT5 Execution.

Please note that the following descriptions of order types do not apply to all types of financial instruments and might apply only to CFD trading. We might not give the option to our clients to place orders for transmission in all the following ways.

Market Order

A client instruction to us in which we make every effort to execute at the best available and prevailing price. Generally, this order will be executed immediately, however, the price at which a market order will be executed has no regard to price changes, and may be exposed to risk of execution and be filled at a worse or better price, known as negative or positive slippage. The Client may attach a stop loss and/or a take profit and/or a trailing stop after the market order is executed.

If a client experiences or suspects any errors with their order aside from slippage, the client should contact our Reception, Transmission and Execution of Orders Department immediately.

This type of order opposes to Instant Order where re-quoting exists.

Market Range

When a client is sensitive to price execution, with market range she can determine a comfortable range of prices in units where her order can execute. See Max Deviation. If her order can execute at a price in the selected range (based on available liquidity), it does, if not, it cancels. Range is only for mitigation of negative slippage.

Pending or Entry Order

An order to be executed at a later time and a price that the client specifies. When the price reaches the price specified by the Client, then the order becomes a market order, as so, negative and positive slippage applies to pending orders. Because the pending or entry prices have been specified by you, this element will not rank first in our best consideration. The client has the option to place the following pending or entry orders:

Buy Limit Order

A pending or entry buy order placed below the current market price. If the market price drops to the level of the buy order that order is then executed.

Buy Stop Order

A pending or entry buy order placed above the current market price. If the market price rises to the level of the buy order that order is then executed.

Sell Limit Order

A pending or entry sell order placed above the current market price. If the market price rises to the level of the sell order that order is then executed.

Sell Stop Order

A pending or entry sell order placed below the current market price. If the market price drops to the level of the sell order that order is then executed.

Trailing Stop Order

A stop loss order set in terms of points (or pips) levels below the market price – for a long position and above the market price – for a short position. The trailing stop price is adjusted as the price fluctuates.

See MT5 Execution for an important feature of the platform on Trailing Stop Order.

Because the stop price has been specified by you, this element will not rank first in our best consideration.

Examples of other types of specific instructions include:

Good ‘til Cancelled (GTC) Order (Expiry)

A setting that the client may apply to ‘entry orders’ The order may remain live and pending execution until such times as the order is executed and treated as market order or cancelled by the client.

Good ‘til [to]Day (GTD) Order (Expiry)

A setting that the client may apply for ‘entry orders’ to be valid only during one trading day. With the end of the day all pending orders are deleted.

Algorithmic Orders

Coverdeal Holdings Ltd does NOT facilitate proprietary algorithmic order types. For the use of Expert Advisors see MT5 Execution.

OUR EXECUTION VENUE CURRENTLY IN USE

We rely on Safecap Investments Ltd as our Execution venue, as Dealer Venue it might use Execution Venues for its dealing on own account. By default, all trades executed on behalf of our client will be executed with Safecap Investment Ltd by us on a ‘Matched Principal’ basis.

If our Dealer Venue were to execute our trades on your behalf on an Execution Venue of its selection, we would be acting as ‘Agents’ and we will regularly and independently review the Execution Venue(s), looking at post trade analytics and periodic monitoring. In addition, we would review our Dealer Venue selection process in order to provide our clients with an additional and independent monitoring process to help ensure that we are taking all reasonable steps to deliver the best possible result in execution for our clients.

We are aware that we have a single Execution Venue, and so we must apply rigorous checks to our Dealer Venue to ensure that they are consistently able to deliver Best Execution for our clients.

Dealing on Quotes

CFDs are derivatives and you trade OTC derivatives with us, therefore you are trading on ‘our’ or ‘our Execution Venue’ prices. (Safecap Investment Ltd is the counterparty or Principal to all of our executed transactions on your behalf). There are a number of factors, that our Dealer Venue’s feeds or liquidity providers or our Execution Venue itself can use in order to construct a derivative price, and these will vary depending on the asset class or underlying product traded, the nature of the market where it trades, the characteristics and terms of the transaction and any special market or credit risk or other premium posed to it.

We will be monitoring prices with benchmarks to ensure that the prices that you are receiving with us are always consider the best prices we can obtain on your behalf.

Dealing on quotes or Quote-driven markets are those where prices are determined by Systematic Internalisers, Market Makers, Dealers or Specialists as opposed to Order Driven Markets where individual investors bid and ask for number of shares or units displayed.

Our Aggregation Policy

Aggregation means that our Dealer Venue may combine our instruction in your behalf, (for example, an instruction to close a Contract in relation to a Non-Guaranteed Take Profit) with those of other clients of the Dealer, or its own orders for the purposes of hedging other client activity, for execution as a single order.

Once an order is received, we will execute your order as soon as is practicable.

A Coverdeal Holdings Client’s order may be at the discretion of our Dealer Venue aggregated with its own orders, its clients’ orders or orders of any other of our clients, in that case, we will disclose to our client whose order is to be aggregated that the effect of aggregation may work to its disadvantage in relation to a particular order.

We may aggregate the orders of a client with those of another of our clients under the following conditions:

1. The orders to be aggregated are of the same type (e.g. buy, sale, underlying product, etc.)

2. Aggregation is only allowed if the orders are placed as limit orders and the prices specified therein are the same;

3. We comply effectively with this Policy.

Warning: Aggregation may on some occasions result in the client obtaining a less favourable price than if the client’s order had been executed separately or together, as applicable. See our Conflict of Interest Policy.

Our Quality of Execution Obtainable at Times of Market Stress

Best execution applies and remains valid at times of market stress. However as mentioned before changes in liquidity and the volatile nature of financial markets, under conditions due not only to news announcements, economic events, market openings/closings, and rapid price movement where to such an extent that under the rules of the relevant exchange where the underlying products are traded and prices are made, trading is suspended and restricted, can have a SEVERE impact on the achievable quality of execution or even the ability to execute orders. These might make difficult to achieve best execution for our clients in the same way as it is expected in normal market conditions. We will try to achieve best execution during those times, and we will recur even to aggregation if needed, in order to act in the best interest of our clients.

THE RISKS YOU FACE WITH EXECUTION

It is in our interest to provide you with the best possible execution, and to inform you about the execution risks involved in trading, regardless of your previous experience.

Information detailing the execution risks associated with our execution approach is as follows:

CFDs (“Contracts for Difference”) on Virtual Currencies

Warning:A cryptocurrency is a virtual currency that is not issued or backed by a central bank or government. They have experienced significant price volatility in the past which, in combination with leverage, places you at risk of suffering significant losses and potentially losing all your invested funds.

CFDs are leveraged product which are complex, extremely high-risk and highly speculative investment. You should be aware of the risks involved and fully consider whether investing in cryptocurrency CFDs is appropriate for you.

Cryptocurrency CFDs are not appropriate for all investors. You should only invest if you are an experienced investor with sophisticated knowledge of financial markets and you fully understand the risks associated with CFDs and cryptocurrencies. You must be fully aware of, and understand, the specific characteristics and risks in relation to these products.

Opinions

We hold authorization by CYSEC to provide the Ancillary Service of:

  • Investment research and financial analysis or other forms of general recommendation relating to transactions in financial instruments.

However, any opinion, news, research, analysis, PRICES, or other information we provide is Market Commentary and does NOT constitute investment advice. We do NOT hold such authorization by CYSEC to provide this investment service.

Internet (Online, Electronic) Trading

There are risks associated with using an internet based deal-execution trading system, including, but not limited to, the failure of hardware, software, and internet connection. We cannot control failures, distortions or delays when trading over the internet.

Coverdeal Holdings Ltd and our Execution Venue employ backup systems and contingency plans to minimize the possibility of system failures, which include in our side, receiving clients’ orders via the phone during specific occurrences, such as technical malfunctions.

Markups or markdowns

We pass onto our clients the prices provided by our Execution Venue with markups or markdowns, (which together with commissions that may apply) act as our service compensation for executing your order. See globtrex.com for more information.

Warning: there are certain limitations to liquidity that can affect the final execution of your order.

Slippage

We expect to get orders filled at the requested rate by our clients. However, there are times when, due an increase in volatility or volume in the underlying product, orders may be subject to slippage.

Slippage as the difference between the expected price of your trade, and the price the trade actually executes at, most commonly will occur during fundamental news events or periods of limited liquidity. Instances such as trade rollover or swap charge are known as periods in which the amount of liquidity tends to be limited as market participants settle their transactions for the day.

During any period of market stress, your order can have an impact on the overall execution you receive.

Stop orders become market orders available for execution at the next available market price. Stop orders guarantee execution but do not guarantee a particular price. For mitigation of risk associated with slippage see MT5 Execution, Market Range and Max. Deviation.

Liquidity

Except during the trading sessions of Tokyo, London and New York, markets tend to be illiquid, these markets may result in wider spreads, as there are fewer buyers and sellers and therefore no prices to make a market. Around rollover times (21:00 GMT) market makers and liquidity providers come offline to settle trades and this also results in wider spreads due to a lack of liquidity. For execution of trades sufficient liquidity must exist to execute all trades at any price, in illiquid markets, clients may find it difficult to enter or exit positions at their requested price, experience delays in execution and receive a price at execution that is a significant number away from your requested price.

As in all markets, some instruments will have greater depth of liquidity than others. High liquidity allows to consistently enter and exit positions near the requested price with minimal slippage during normal market conditions.

These risks may be considered by any client into their dealing strategies and decisions. This is why the use of advanced orders types can help to mitigate these risks.

Delays

Delays in execution may occur because of technical issues with the client’s internet connection to our servers, a delay in order confirmation from our Execution Venue; or by a lack of available liquidity for the instrument that the client is attempting to trade. In order to diminish this risk, our clients must have a working and reliable internet connection.

We will make every effort to process orders within milliseconds; after verifying that your account holds enough margin to open the requested transaction, although, there is no exact time frame for order processing, and execution of an order by our Dealer Venue may take up to 8 seconds.

In case if delays due to abnormal order processing or malfunctions with internal or external process, we will notify you as quickly as possible, depending of the complexity of the issue.

Orders Reset

Certain types of orders as Limit orders (Take Profit) would not execute during low liquidity, but instead reset until the order can be filled. In this way these type of orders guarantee price but do not guarantee execution. Depending on trading strategy and market conditions clients may be more concerned with execution versus price or vice versa.

Widened Spreads

There are instances when spreads widen beyond the typical spread. As we mentioned before spreads are a function of liquidity, responding to uncertainty in the direction of prices or to an increase in market vitality.. Knowing liquidity patterns, as rollover sessions, and taking them into confirmation while trading with OPEN ORDERS (see below) or placing new trades around these times can diminish your trading risks.

Widened spreads may only last a few seconds or as long as few minutes. Trading around times of market stress demands caution and our clients must always be aware of their account equity, usable margin and market exposure. Widened spreads can adversely affect ALL positions in an account, and may result in margin calls on your account.

Hanging Orders

During high traffic of volume of orders, hanging orders may occur. This is a condition where an order is in the process of executing but execution has not yet been confirmed. During periods of heavy trading volume, it is possible that a queue of orders will form. That increase in incoming orders may sometimes create conditions where there is a delay from our Execution Venue in confirming certain orders. Depending on the type of order you are placing, outcomes may vary, and the position may have in fact been executed, despite a window indicating processing, the delay being simple due to heavy traffic.

Attention: Keep in mind that is only necessary to enter any order once. Multiple entries for the same order may slow or lock your computer or inadvertently open unwanted positions.

Rollover and Swap Charges

These terms refer to interest charged or applied to clients’ accounts for positions held overnight, meaning 21:00 GMT, the time when the fee is debited or credit to the account.

Is important to note that charges will be higher than accruals. Clients must manage positions accordingly as charges may affect existing and open positions and margins available.

Inverted Spreads or Lag Feeds

In rare cases quotes feeds can be disrupted. This may only last for a moment. During this occasions we request from clients to avoid placing orders as market orders., while it might be tempting to place a ‘free trade’ you must keep in mind that prices are not real and the actual fill may be many units away from the displayed price.

In the case that a trade is executed at rates not actually offered by our Execution Venue, we reserve the right to reverse such trade, as they are not considered a valid trade.

Gapping

Prices can display gaps from previous sessions closes and most common Sunday’s opening prices may or may not be the same as Friday’s closing prices. At times, the prices on the Sunday open are near where the prices were on the Friday close. At other times, there may be a significant difference between Friday’s close and Sunday’s open. The market may gap if there is a significant news announcement or an economic event changing how the market views the value of a currency. If you are holding positions or orders over the weekend, you should be fully comfortable with the potential of the market to gap.

Simultaneous Long Short Strategy

The ability to ‘offset’ exposure on a trade allows a client to hold both buy and sell positions in the same underlying product simultaneously. You have the ability to enter the market without choosing a particular direction for an underlying product. While the ability to ‘offset’ exposure is an appealing feature, you should be aware of the factors that may affect such positions.

Diminishing Margin

A margin call may occur even when exposure in an account is fully ‘offset’, since spreads may widen, or rollover and swaps may be charged causing the remaining margin in the account to diminish. Should the remaining margin be insufficient to maintain any open positions, the account may sustain a margin call, closing out any open positions in the account. Although maintaining a long and short position may give the client the impression that his exposure to the market’s movement is limited, if insufficient available margin exists and spreads widen for any period of time or rollover and swaps charges are applied, it may certainly result in liquidating all positions.

Chart Pricing and Prices displayed in the Platform

There is an important distinction between indicative prices and dealable prices. Indicative prices often offer an indication of the market and the rate at which prices are changing. These process may be derived from contributors from the market that may not necessarily reflect those from where our Safecap Investments Ltd’s Execution Venues are making their prices.

Dealable prices ensure finer execution and because CFD trading is an OTC Derivate market each Dealer may quote slightly different prices. See Dealing on quotes.

Therefore, any prices displayed by a third party charting provider, which does not employ our Execution Venue’s price feed, will reflect indicative’ prices and not necessarily actual ‘dealing’ prices where your trades can be executed.

Mobile Trading

Mobile trading technology has more inherent risk associated with it, as duplication of order instructions, latency in prices provided and other issue that are a result of mobile connectivity.

OUR MT5 EXECUTION

Please read carefully the below information as it details aspects of execution, trading features, and platform setting specific to the MetaTrader 5 Platform we offer.

Features and Settings

Tradable Underlying Products: 277

GMT Servers Offset: 22:10:00

Default Tradable Size: 0.01

Stop Loss and Take Profit Restrictions: Yes

Pending Order Restrictions: Yes

Scalping Restrictions: None

Simultaneous Long Short: Yes

Close Part of a Position: Yes

Max Deviation: N/A

Default Deviation: Market Execution

Default Order Type: Kill or Fill

Default Execution Model: “Matched Principal” also known as “Riskless Principal”

MT5 Trade Execution

Instant / Market Order

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Pending Orders

Buy Stop

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Sell Stop

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Stop Loss

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Commission: May Apply

Markup or Markdown: Yes

Buy Limit

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Sell Limit

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Take Profit

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Buy Limit Order

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Stop Limit Order

Execution: Market Order

Re-quoting: No

Slippage: Yes

Partial Fills: No

Level Restrictions on “Stop and Limit” Orders: Yes

Markup or Markdown: Yes

Open/Close, Take Profit, Stop Loss and Margin Call Execution

Orders to open and close trades, as well as take profit orders execute Fill or Kill. These orders only execute if they can fill in their entirety at market price. These orders cannot be broken up and filled at multiple prices.

Execution will cease in the event that sufficient liquidity is not immediately available to execute a Fill or Kill order in its entirety.

Stop Loss orders, and orders submitted by Margin Call do not execute Fill or Kill. These orders do fill in their entirety at the same price

Execution will continue in the event that sufficient liquidity is not immediately available to execute a stop loss or margin call until a price becomes available to fill the order in its entirety.

The maximum number of open orders is not currently capped at any number of individual orders per account. This no restriction includes both open orders and pending orders. We reserve the right to cap an account at any amount of individual orders, both open orders and pending orders.

Depending on the underlying product our MT5 allows for order sizes up to 3 million per trade. Clients have the ability to trade incremental sizes (multiple orders of up to 3 million for the same underlying product).

MT5 Trailing Stop Order

Please be aware that in case the MetaTrader 5 terminal is closed, trailing stops will not work. This happens as the trailing stop works on the client terminal side and in this respect, if the client terminal is closed, only the stop loss that was placed by trailing stop before the closing of the terminal can execute.

MT5 Limit and Pending Order(s)

You can NOT use a limit or pending order to close a trade or a portion of it. Limit and Pending orders can only be used to open new trades. For example, the same total or partial size limit or pending order in an opposite direction will automatically cancel, leaving the existing trade unaffected.

Our MT5 Margin Call Policy

You will receive a Margin Call when Free or Available Margin reaches 100% or falls below this level. Trades will start to be liquidated and close one by one at the time Free or Available Margin equals or falls below 5% and until Free or Available Margin is again greater than 100% level.

After Margin Calls and prior to liquidation of open positions we do not provide a warning to our clients.

The result of any margin call if not taken care of, is subsequent liquidation unless otherwise specified.

The idea of margin trading is that your margin acts as a good faith deposit to secure the larger notional value of your open position(s). margin trading allows you to hold a position much larger than the actual account value.

Warning: Trading on margin comes with risk as leverage may work against you as much as it works for you.

Our liquidation process is entirely electronic, and there is no discretion on our part as to the order in which trades are closed. There might be instances when liquidity does not exist at the rates of the Margin Call; as a result, equity can fall below the margin requirements at the time orders are filled, even to the point where account equity becomes negative, this is especially particular during market gaps or market stress. See Negative Balance Protection.

Stop orders limit the downside risk instead of Margin Calls being used as final stops.

With margin calls clients agree to pay on demand such sums by way of margin as are required from time to time as in our and our Dealer venue(s)’ reasonable discretion requirement for the purpose of protecting ourselves against loss or risk of loss on present, future or contemplated transactions under our services.

Clients should maintain the appropriate amount of Margin in their accounts at all times. Margin requirements can change based on account sizes, simultaneous open, positions, trading style, market conditions, underlying product, and at our discretion.

Margin calls are a requirement, not a courtesy, in that sequence, email and SMS alerts are designed to inform a client whose accounts’ equity drops below Margin requirements which can potentially give her extra time prior to all open positions being liquidated due to an unattended Margin Call.

However, you should not rely on receiving alerts and you should monitor your account at all times as we are not liable for any communication failures or delays.

Warning: Margin calls often occur due to over leveraging. Using more leverage can increase your gains, but it can also increase losses, which will quickly deplete your usable margin. The more leverage you use, the faster your losses can accumulate.

While trading CFDs on margin, time is not on your side, as they are not suitable for a ‘buy and hold’ strategy. CFD trading on margin requires constant monitoring over a short period of time such as minutes, hours or days. You are exposed even to overnight risk. Our products require active management from your side.

When receiving a Margin Call, your account will be locked from opening any new positions and any entry order which should have been executed while on this status, will be deleted and not executed unless that order is meant to close out any open position.

In order to bring back account equity above the Maintenance Margin Requirement Level mentioned before or deal with a Margin call, our clients have a few options:

  1. You deposit more funds to bring your equity back above the Maintenance Margin Requirement of Free or Available Margin above 100%.
  2. You close out positions which brings your equity back above your Maintenance Margin Requirement of Free or Available Margin above 100%.
  3. You do nothing and;
  1. Market turns in your favour bringing your equity back above the Maintenance Margin Level of Free or Available Margin above 100%.
  2. Market moves further against you reaching the Liquidation (Close) Level of Free or Available Margin equal or falling below 5%.

Negative Balance Protection

Our products incur a high level of risk and can result in the loss of all the client’s invested capital, however, it should be noted, that we operate on a negative balance protection basis which means that you cannot lose more than your overall invested capital.

Your Explicit External Costs

Interest Rates are not displayed on the MT5 Platform, however, trades will pay or accrue interest in accordance with our Dealer Venue rates. To obtain the rollover rates you can contact our Reception, Transmission and Execution of Orders Department. Please be advised that interest rates are provided to our Execution/Dealer Venue by multiple sources and every effort will be made to display rollover/swaps rates on time, you are reminded that during times of extreme market volatility, rates may change intraday.

Any positions that are open 21:00:00 GMT sharp are considered to be held overnight, and are subject to rollover. A position opened 21:00:01 GMT is not subject to rollover until the next day, while a position opened at 20:59:59 GMT is subject to rollover at 21:00:00 GMT.

Coverdeal Holdings Ltd MT5 Platform does NOT show units or pips costs.

EAs or Expert Advisors

Expert Advisors (EA) are automated trading tools that can perform all or part of a trading strategy.

Coverdeal Holdings Ltd does not offer in-house or proprietary EAs and there are some developed by third parties. We do not vouch for the accuracy or reliability provided by EAs as these are not in our control. Clients using an EA do so at their own risk. The trade sizing of your EA might not be compatible with our platform. Prior to trading please check with your EA provider to discuss the trade sizing used in your program in order to identify any issue that may arise from trade size compatibility.

Web Platform Compatibility

Coverdeal Holdings Ltd account holders can place and manage orders through the company’s offered platforms. Account details for clients (e.g. Orders, Profit and Loss, Margin, Equity) will match in all of these platforms and their statements of records. However please note that some functionality available on the MT5 platform may not be available on the Web platform and vice versa.

Our MT5 Server Information

If you have download the MT5 platform from our website, you will not need these server addresses.

If you need to enter the server address when logging in, be sure to use the one that corresponds to your trading account.

MT5 Live Server: live03-fr1.meta-services.com:443

Our Review of this Policy

We will review this policy at regular intervals and at least annually and whenever a material change occurs that affects us to continue to comply with our regulatory obligation to obtain the best possible result for the execution of clients orders.

If at any time we identify any deficiencies, we will take appropriate remedial action and where necessary amend this policy.

A material change is defined as one of the following:

  • Addition or removal of an Execution Venue.
  • Significant change to the operation of an Execution Venue.
  • Addition or removal of a Financial Instrument.
  • Significant change to the way a Financial Instrument or Underlying Product is traded, priced, etc.
  • Any other parameter that affects our ability to obtain best execution.

Our review will take into account the regular review of the execution quality and Execution Venues carried out by our Dealer venue on whom we rely to execute our client’s orders.

Amendments to this policy shall be effective immediately. We shall whenever possible give you advance notice of any changes we make to this Policy, in case this may not always be possible, we invite you to constantly return to this Policy. The latest published version of this Policy can be found on our website at all times.

By commencing trading with us, you will be deemed to have consented to the contents of the current version of this Order Handling, Allocation and Execution Policy.

We remind you that our commitment to provide you with ‘Best Execution’ does not mean that we owe you any fiduciary responsibilities over and above the specific regulatory obligations placed upon us or as may be otherwise contracted between us.

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Risk Warning: Trading CFDs is risky and can result in the loss of your invested capital. Please ensure that you understand the risk involved and do not invest more than you can afford to lose. Read full Risk Disclosure Statement .Coverdeal Holdings Ltd is regulated by CySEC under License No. 231/14
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