Best Execution Policy
Preliminary Note
Unless otherwise indicated, all capitalized terms used in this policy have the same meaning as in the Customer Account Agreement governing your account agreement with Shakepay Inc. (“Shakepay”).
This best execution policy (“Policy”) is intended to provide you with:
a general explanation of the factors taken into account by Shakepay to obtain best execution, including a description of the spreads charged by Shakepay;
a description of Shakepay’s policies regarding spread management and reimbursement circumstances and conditions; and
a description of any material conflicts of interest that may arise when sending client orders for handling or execution and how these conflicts are managed by Shakepay.
Purpose
As an investment dealer regulated by the Canadian Investment Regulatory Organization and specializing in crypto assets, Shakepay must carefully execute client orders.
There is no fixed market or universally accepted benchmark to evaluate the best execution of crypto assets. Best execution in this Policy means obtaining for our clients the most advantageous execution terms reasonably available under the circumstances, considering prevailing market conditions.
Shakepay uses wholesale crypto asset trading facilities (“Liquidity Providers”) to purchase or sell crypto assets as principal. Shakepay’s Liquidity Providers may change from time-to-time as determined by Shakepay.
When you execute a trade on Shakepay’s application platform (the “Shakepay Platform”) Shakepay will sell to you, or buy from you, crypto assets, acting as principal. This means that your counterparty to such trades is always Shakepay, and not a third party or another customer of Shakepay.
This Policy sets out the ways Shakepay intends to achieve the best possible results for its clients when executing their orders.
Scope
This Policy applies to all customer orders accepted by Shakepay, unless otherwise agreed between the client and Shakepay.
An “Order” means the instruction given to Shakepay by a client to buy or sell crypto assets for the client’s account. Shakepay accepts and/or executes the Orders on an execution-only basis for its client. This means that you are solely responsible for your investment decisions.
Policy
Shakepay’s Pricing and Order Types
Pricing of crypto assets made available by Shakepay is set on a dynamic and ongoing basis. When you want to buy or sell crypto, the Shakepay Platform algorithm obtains current prices for the crypto asset from an aggregation of pricing information received from Shakepay’s Liquidity Providers (the “Pricing Aggregation”), after which it incorporates a spread to compensate Shakepay (the “Shakepay Mark-up”), and then presents a price to you.
If you wish to trade at a price presented by the Shakepay Platform, you will confirm that you wish to proceed and your market order at the quoted price will be filled on the Shakepay Platform. The price presented to you will be refreshed based on new pricing obtained by Shakepay from Shakepay’s pricing algorithm based on the Pricing Aggregation approximately every 30 seconds.
Because the price refreshes every 30 seconds on a fixed schedule, it is possible that you may open the Shakepay app and request a quote during the 30-second cycle but fail to execute a trade before the 30-second cycle ends and a new price is generated. In that case, Shakepay honours the first price shown to you as long as the difference between the first price shown and the updated price does not exceed 30 basis points (0.3%). If the difference between the first price shown and the updated price is greater than 30 basis points, then the trade does not execute and Shakepay will present you with a new price and request that you re-submit your order based on the updated price.
Shakepay also permits two ways to place an Order that will or may be executed in the future or upon the satisfaction of certain conditions, namely a “Limit Order” and “Recurring Buy Order”.
A “Limit Order” will execute at a later date or time when the price available to customers on the Shakepay Platform drops below your set limit price value, in the case of an Order that is a purchase of Crypto Assets, or it rises above your set limit price value, in the case of an Order that is a sale of Crypto Assets.
A “Recurring Buy Order” will periodically execute a purchase Order according to your desired recurring time period, such as every day, week or month.
A Limit Order or a Recurring Buy Order will not be fulfilled if you have insufficient funds in your account.
Execution Factors
When executing Orders for you, Shakepay will take reasonable steps to achieve the best possible result for you. Shakepay considers the following factors to be part of its reasonable steps when execution an Order:
the price of the crypto asset, meaning the market price at which the Order in the respective crypto asset is expected to be executed based on pricing information available to Shakepay;
the speed of execution, meaning the time required to execute the Order;
the certainty of execution of the order;
the order type, including instructions provided by you; and/or
the overall cost of the transaction.
Shakepay executes orders at all times, 24/7, unless exceptional circumstances occur.
Spread Management
Shakepay monitors and evaluates the quotes it obtains from its Pricing Aggregation on an ongoing basis.
In order to achieve best execution for Orders, Shakepay seeks to ensure that the quoted price of Crypto Assets on the Shakepay Platform at any moment (including any mark-up imposed by a liquidity provider plus the Shakepay Mark-up) is within 3.5% or less when compared to Shakepay’s benchmark price (namely a third party benchmark reference rate selected by Shakepay from time-to-time) (the “Benchmark Rate”). However, in volatile markets the combined spread can occasionally be greater than 3.5%. In such cases, Shakepay will reimburse you so that the actual spread charged to you is effectively reduced to 3.5% over/under the applicable benchmark price as determined using the Benchmark Rate (“Benchmark Price").
In all cases, the materiality threshold for a reimbursement to apply is $10. Below that amount (on a per trade basis), Shakepay does not pay a reimbursement.
Shakepay targets a spread ranging between 0.5%-2.0% over the Benchmark Price, depending on market conditions and liquidity. In the event of adverse market conditions or liquidity constraints , the spread may be increased by up to an additional 1.5%. Shakepay considers this spread over the Benchmark Price (taking into account that a portion of that spread is taken by the Liquidity Provider) is fair and reasonable, considering the fair market value of the crypto assets at the time of the transaction, the expense involved in effecting the transaction (such as foreign exchange costs), the fact that Shakepay is entitled to a profit, the prices of competitors and the total dollar amount of a given transaction.
Selection of Liquidity Providers
Liquidity Providers are subject to a due diligence review process which is overseen by an internal committee. Shakepay monitors and reviews the performance of its Liquidity Providers to ensure that these remain suitable for Shakepay’s business. Shakepay will reconsider its available Liquidity Providers where a Liquidity Provider fails to meet Shakepay’s requirements.
Order Processing Principles
Shakepay executes Orders in a timely, fair and non-preferential manner and does not systematically favor large Orders over smaller ones or Orders of certain clients over those of other clients and non-clients, such as Shakepay’s personnel.
Shakepay applies the following principles to order processing:
Orders are registered and allocated promptly and correctly; and
comparable Orders are executed in the sequence they have been received;
Shakepay does not aggregate Orders.
Shakepay does not receive inducements from execution venues and trading counterparties, and its relationship with Liquidity Providers is one of customer and wholesaler.
Conflicts of interest
Shakepay has carefully considered its relationships with Liquidity Providers and has determined that they do not pose any conflicts of interest. Shakepay does not hold an economic interest in any Liquidity Provider.
Shakepay is committed to ensuring that all clients receive fair treatment and the best available execution for their orders, regardless of the order size or execution method.
Help Desk
Shakepay’s app and trading platform is designed to be easy to use. In the event that you require assistance, you can reach out to the Shakepay support team via the Support Chat function in the app or on the Shakepay website or by email at support@shakepay.com. Support Chat and email support is available weekdays from 9am – 9pm ET, and weekends from 9am – 6pm ET.
Amendments
Shakepay regularly monitors and assesses the effectiveness of this Policy. We reserve the right to amend the Policy at any time, with any updates promptly published on Shakepay’s website.
The latest version of the Policy will always be accessible on our website.
Last update: January 8, 2025
Last updated