Coinsquare Capital Markets Limited (d/b/a “Bitbuy”), as a Dealer Member of the Canadian Investment Regulatory Organization (“CIRO”), is required under CIRO Rules to establish, maintain and ensure compliance with written policies and procedures that are reasonably designed to achieve “best execution” when acting for a client. This Best Execution Disclosure is intended to provide a clear and easy-to-understand summary of the measures that Bitbuy takes to achieve “best execution” for client orders — which means obtaining for our clients the most advantageous execution terms reasonably available under the circumstances, considering prevailing market conditions.
The determination of whether best execution has been achieved is subject to reasonable efforts and should be interpreted in the context of the following broad factors:
Bitbuy will also review all executions via a spread execution exception report which will measure the quote given to clients versus the underlying quote to Bitbuy, to review any instances where the quote is more than a 385 bps difference.
Any such instances will be investigated, and unless the client gave permission for the higher spread, the client will be rebated the difference in Canadian Dollars (CAD) to remedy the situation, and a review of the trading parameters will be done to ensure systems are operating as intended within the intended spread.
Additionally, Bitbuy will review all executions via an exception report which will compare the quote given to clients against the available pricing on the Coinsquare Capital Markets Limited ATS. The report shall return an instances where a discrepancy exists of $1 or greater. If any such instances are found, the affected client shall be compensated the Canadian dollar equivalent of the difference between the benchmark price that was used to generate the quote in Bitbuy Trade, and the price that was available on the ATS at the time of execution.
Bitbuy diligently pursues the execution of each and every client order; however, different kinds of orders may be handled differently, depending on the type of order and the way in which it is submitted to Bitbuy by the client. For example:
Unlike equity securities (stocks), which are listed on a stock exchange, digital assets are not “listed” on any single marketplace, but rather, they exist on the blockchain and are traded globally by and through a variety of intermediaries. Bitbuy uses a variety of measures to ensure that your trades through Bitbuy Trade will always execute at the best price available under the circumstances that prevail at the moment when you confirm your trade.
In establishing the quote, which is the price at which Bitbuy will buy a digital asset from you, or sell a digital asset to you, Bitbuy:
The quote you receive is guaranteed for ten (10) seconds; if you confirm the trade within that 10-second period, Bitbuy will execute the trade using that quote as the execution price. After 10 seconds, the original quote will automatically become stale and be replaced by a new quote. This will repeat every 10 seconds until you confirm the trade or you decide not to trade at all.
In sum, Bitbuy looks at the available prices in global markets at each step in the process so that it can provide you with the best price available at any given moment. However, until you confirm your trade, the price that we quote you is subject to change, in line with market fluctuations.
You should also be aware that:
Bitbuy is registered and operates as an CIRO-approved investment dealer, but it also has regulatory approval to operate a marketplace that is an alternative trading system (or “ATS”), which it operates as a separate business entity. When providing services to you as a retail client, Bitbuy is operating as a dealer; in contrast, the services of the ATS are only offered to other CIRO dealers and large institutional investor firms. While the dealer and ATS businesses are both operated through a single corporate entity (which is a wholly-owned subsidiary of Coinsquare Ltd.), each business unit has its own employees, and trading information is never shared between the two business units. Moreover, the Bitbuy dealer will never receive any preferential treatment as compared to other dealers that may trade on the ATS. For additional details on how Bitbuy has addressed all potential conflicts between its dealer and ATS businesses, please see the ATS Conflict of Interest Policies and Procedures and Dealer Conflict of Interest Policies and Procedures, which are available on the Bitbuy website: https://bitbuy.ca/.
Bitbuy reviews our “best execution” policies and procedures, including this Best Execution Disclosure, at least annually.
Should you have any questions regarding this Best Execution Disclosure or any policy it describes, please email our Support team at support@bitbuy.ca.
