TeleTrade-DJ International Consulting Ltd (“the Company”), being licensed to operate in the European Union (EU) under the MiFID passport, is becoming subject to the updated and revised MiFID legislation, the Markets in Financial Instruments Regulation and Cyprus Law 87(I)2017 regarding the provision of investment services and the exercise of investment activities (collectively, “MiFID II”) as of January 3, 2018.

TeleTrade would like to inform you of the changes in their conduct of business that result from the above legislative and regulatory developments, and provide you with legal disclosures and acknowledgements pertaining to the above.

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With the new MiFID II legislation, you may note the followings.

1. Your MiFID II category

Your client category under MiFID I remains unchanged for MiFID II purposes. If you believe that your categorization is not appropriate for you, or you would prefer not to enjoy protections available to the Retail clients under the law, or should your situation change, please contact the support team. Please note that this category is applicable until further notification from us.

2. Provision of Services to Legal Entities

Beginning with January 3, 2018 we will only be able to offer trading in CFDs on exchange-traded assets (including Metals, Commodities, Stocks, ETFs, Indices) to legal entities who have a valid LEI number. Legal entities that do have LEI or decide to obtain one, are kindly asked to input it in their Personal Page > General Information about the Company, or send it to us by a ticket from your personal page or by email to the support team. Their clients-legal entities that don’t have a LEI number will still be able to trade all Forex pairs.

3. Reporting of Transactions to Competent Authorities

According to the reporting requirements of MiFID II, TeleTrade must report to the Cyprus Securities and Exchange Commission (“CySEC”), information about your transactions in financial instruments the underlying of which is traded on regulated markets (e.g CFDs on Stocks, Indices and ETFs etc). Such information will include your personal detail, such as first name, last name, country of citizenship, date of birth and other personal identification data (e.g. national passport number). For legal entities, LEI code will need to be reported along with the name, surname and date of birth of the legal entity’s decision-maker with respect to its account with TeleTrade. Your continued use of our services for trading in the abovementioned financial instruments will be construed as acceptance of the requirement for disclosure of the said information with the Competent Authorities, and as your consent to thereby agree to waive any rights to confidentiality regarding said information.

4. Investor Protection

As required by MiFID II, the Company will be providing you with additional information and disclosures so as to ensure adequate protection of your interest. Such disclosures will include:

a) disclosures on trading costs

TeleTrade will be providing ex-ante information on transactional costs that you may need to choose the most appropriate account type for your needs and plan your investments accordingly. Beginning January 3, 2018, we will start disclosing cost transparency information, for different account types, showing the actual average impact of transaction costs on net profitability of a client account, on the basis of actual costs and charges levied from client accounts during the previous quarter. Such information will be publicly available on the TeleTrade web-site, and will be updated on the quarterly basis.

b) disclosures on quality of execution

According to our Best Execution Policy, major execution factors that influence the quality of our service are price and likelihood of execution of the client orders. TeleTrade will be disclosing, at its web-site, the execution quality scorecard for the above factors on quarterly basis, for all types of accounts, based on the actual performance data as of the quarter passed. Statistics will include all valid market and pending/limit order requests received via MetaTrade platform, excluding trader orders received by voice or in writing.

c) reporting of transactional expenses of an account

For every account active during a year, the Company will be providing, in the end-year account statement for 2018 and on, a personalized summary of all costs and charges incurred in the account with respect to provision of investment services and ancillary services that were a part of our ongoing relationship with you during the year.

d) information about execution venues

TeleTrade will inform you, on annual basis about the available information in relation to the top five execution venues/brokers (where we place orders with third parties) used.

e) notification of position and account depreciation

Under the new reporting requirement under MiFID II, in case where your account that includes positions in leveraged financial instruments or contingent liability transactions (e.g. Contracts For Differences “CFDs” and rolling spots), the Company will be informing you where the initial value of the position depreciates by 10% and beyond, by comparing the open P/L on a position with the required margin for opening that position with a standard fixed leverage of 1:100. All and any open positions with floating losses in excess of 10% of the initial margin will be highlighted in the daily trading statement submitted to your email addresses for your attention and action.

For Clients using TeleTrade Invest service, additional notification will be issued where the overall value of the trading account connected to the service depreciates by 10% within the monthly reporting period, and thereafter at multiples of 10%, no later than the end of the next business day in which the threshold is exceeded.

5. Product governance

Our new responsibility under MiFID II is to assess and define a target market of all the investment products that are manufactured for, distributed or sold to you, and also to performing a preliminary compatibility assessment on each product offered versus your needs, characteristics and objectives. As new products are being manufactured and offered by TeleTrade, your maybe required to provide additional information for us to be able to assess if you fall within a target market for a specific product and whether you should be offered or advertised such products.

6. Communicating with you in the course of the provision of investment services

We hereby inform you about MiFID II extended requirement of recording of telephone and electronic communications as well as your right for accessing those records. Whereas under MiFID we recorded phone and electronic communications with our clients solely with respect to provision of investment services, now the recording requirement extends to include communications with that either resulted or might result in transactions in financial instruments. Therefore, the content of your electronic communications with the Company may be recorded in cases if those concern matters that can reasonable be expected to result in transactions in financial instruments. These recordings may be made with or without the use of a spoken warning, tone, or similar notification.

7. Required consents

As a result of the upcoming changes envisaged by MiFID II, we request your consent in relation to specific matters so as to ensure compliance with MiFID II and continue trading with you:

1. You consent to your categorization.
2. You confirm that you have regular access to the Internet and you consent to the Company providing you with information in a durable medium other than on paper, either by facsimile transmission, or electronic mail (email) to the number and address that were provided to the Company. In addition, you hereby consent to the Company providing information that is not addressed to you personally by means of the Company’s website.
3. You consent to waive rights to confidentiality regarding your personal information disclosure of which to the Cyprus Securities and Exchange Commission is required within the framework of reporting transactions in financial instruments the underlying of which is traded on regulated markets (e.g CFDs on Stocks, Indices and ETFs etc).
4. You express consent to assess the depreciation of 10% of the value of any leveraged financial instruments and contingent liability transactions (e.g. contracts for difference and rolling spots) and/or of your trading account overall, by accepting disclosures described in section 4e of this communication.

Kindly note that if you do not communicate to the Company any objections and you continue to use their services from 3 January 2018 onwards, you will be deemed to have given your consent in relation to all aspects mentioned above.

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For more information, please contact TeleTrade support team.