Inappropriate order handling
failure to deliver best execution to clients or deliberate and / or negligent behaviour resulting in poor client outcomes when executing their orders
Effective implementation of surveillance alerts for inappropriate order handling requires capturing the following trade data:
trade and position
client orders including relevant specifications and execution details
market prices and volumes
FCA FX market wide remediation programme identified a number of risks related to unacceptable behaviours involving client orders.
General best execution obligations are outlined by various regulators around the globe. MiFID II best execution, Article 27 - Obligation to execute orders on terms most favourable to the client, provides an example of regulatory expectations around handling client orders.