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According to the ZKA level 1 requires that all “reasonable steps” need to be taken in order to achieve best execution of client orders. Since this would involve a considerable amount of additional time and technical effort and lead to a considerable increase of execution costs, the implementing measures need to ensure that the best execution obligation is complied with, so that – in line with the Level 1 provisions – there will be no case by case assessment.
Furthermore, any wide-ranging review obligation would collide with the duty of immediate trade execution. Especially in the case of volatile securities, such a kind of obligation may lead to a situation where, once the review has been completed, prices may already have undergone fundamental change.