MIFID II – Information letter. New edition of the Terms and conditions and amendments in Tariffs

Dear Clients!

Hereby KIT Finance Europe (hereinafter – the Investment firm) informs that starting from 3rd January 2018, Directive of the European Parliament and Council 2014/65/EU referred to as MIFID II, will come into force. The new Directive MIFID II imposes several vital changes to conditions of rendering investment services within the European Union.

Taking into account new requirements and features of our new products and services, new edition of the Terms and Conditions of Rendering Investment Services (hereinafter – the Terms and Conditions), updated tariffs and other implementations will come into force starting from 1st January 2018:

Cryptocurrency

KIT Finance Europe moves cryptocurrency trading to a new level. This market is now available to all our Clients.

Specifically, live quotes are available for free in trading terminal QUIK, while receipt of orders is performed via the phone or Personal Account. Transactions with Bitcoin, Ethereum and other instruments may be performed using RUB, EUR, USD and other currencies on the Client’s account in KIT Finance Europe.

Before executing transactions with cryptocurrencies, it is essential to get acquainted with the risks and features specified in Appendix №14 to the Terms and Conditions and send signed document to clients@kfe.ee or via Personal Account.

Apart from direct transactions with cryptocurrencies, Clients may also trade Bitcoin Futures on CME and CBOE.

Margin Trading

In compliance with the general strategy of KIT Finance Broker Group, KIT Finance Europe significantly decreases RUB interest rates for securities and funds loans. Starting from 1st January 2018, RUB interest rate in KIT-Standard tariff will be only 12.95% per annum.

Moreover, USD interest rate remains the same, despite recent rate hikes implemented by the US Federal Reserve. USD rate in KIT-Standard tariff is 6.9% per annum.

Penny Stocks

Taking into account Clients' requests, the Investment firm have set up the boundary for the maximum commission charged for trades with penny stocks. Commission will not exceed 3% (KIT-Standard tariff) of trade value or the amount of the minimum rate.

MOEX Derivatives market, Custody Services and Other Amendments in Tariffs

Unfortunately, MIFID II, MIFIR (Regulation № 600/2014) and other regulatory directives that will come into force in 2018, brought significant load on activities of investment companies. Considering this fact, KIT Finance Europe is forced to amend a number of commission rates towards increase: in particular, rates for storage of securities, operations on MOEX derivatives market (FORTS) and OTC markets. In addition, commission for maintenance of suspended account is introduced.

On the other hand, AS KIT Finance Europe returned to practice of monthly write-off of commissions for custody services, which will significantly reduce the number of reports sent to Clients.

You may find more information regarding tariffs on our website www.kfe.ee.

KIT Finance Europe has always been open for dialogue with Clients to help find the balance acceptable for both parties either through implementation of individual tariffs for Clients with significant trading volumes or through other means. KIT Finance Europe is faithful to this approach and is always ready to negotiate with Clients trading agreements and tariffs. Please contact your client manager or sales@kfe.ee for detailed information.

Best Execution Policy

Starting from 1st January 2018, in addition to the updated Terms and Conditions of Rendering Investment Services, new edition of Best Execution Policy that reflects the requirements of MIFID II as well as conditions of execution of Clients’ orders, will come into force. KIT Finance Europe kindly asks you to get acquainted with the updated document on our website www.kfe.ee.

In particular, the Investment firm would like to receive confirmation of your consent with the following: (i) KIT Finance Europe (unless established otherwise by the legislation) has the right not to immediately make public any limit order you place with us in respect of shares admitted to trading on a regulated market or traded on a Trading Venue where that order cannot immediately be executed; (ii) execute an order on your behalf outside a Trading Venue where we reasonably believe this is necessary to achieve best execution; and (iii) execute orders you place with us partially; in particular, market orders may be divided into smaller orders, which will be executed separately; (iv) execute orders you place with us in accordance with our Best Execution Policy.

Classification of Clients

General approach to classification of Clients in MIFID II remained the same, although requires additional consent from the Client to earlier issued category (retail client, professional client and eligible counterparty).

Recording of conversations and other messages

KIT Finance Europe keeps records of phone, electronic and other conversations between the Client and employees of the Investment firm and stores these records in accordance with the rules established by the Terms and Conditions and legislation.

LEI Code

In accordance with MiFID II and MiFIR, all legal entities executing transactions with financial instruments are required to have LEI code.

Starting from 3rd January 2018 KIT Finance Europe is prohibited to execute transactions with financial instruments on behalf of legal entities, if these legal entities do not have LEI code.

For the allocation of LEI code and verification of its availability, legal entities are recommended to use www.gleif.org.

KIT Finance Europe also offers the service of allocation and maintenance of LEI Codes. Please contact client management department for the receipt of additional information clients@kfe.ee.

KIT Finance Europe LEI code – 549300HXOCTXFFW8RD19.

Identification Data

Implementation of regulatory requirements for automatic exchange of information, new requirements of 4th EU Directive on combating legalization and terrorism financing (Directive 2015/849), sanction, tax and other regulations enforced corrections to the list of required information provided by Clients and to the forms of identification questionnaires.

Consent

Hereby KIT Finance Europe kindly asks you to confirm your consent with the information provided, recording of calls (messages), conditions of execution of orders as well as updated documents. You may send your consent by any explicit means of communication to clients@kfe.ee.

In case of absence of information from the Client’s side until 03.01.2018, KIT Finance Europe shall consider your consent with all the amendments, new conditions and classifications as valid.

You may find more information regarding updated edition of the Terms and Conditions, Best Execution Policy, tariffs and other documents on our website www.kfe.ee in “Documents” section.

Should you have additional questions or concerns, please do not hesitate to contact client support service clients@kfe.ee.

Thank you for cooperation and wish you a Merry Christmas and a Happy New Year!

Kind regards,
KIT Finance Europe
www.kfe.ee