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so points remains…potentially not best price then?
The regs require you to take “all reasonable steps” to obtain best execution, and explicitly allow you to take into account “any relevant consideration” when deciding what best execution means (not just price). They don’t say you need to onboard every possible executing broker.
That framing of “best” execution sounds like another kind of soft dollar. Ripe for abuse
“Here’s all my trading volume in exchange for your virtue points which I can show off in my marketing to win more AUM”
MIFID II Best Ex went from "all reasonable" to "all sufficient" steps. I'm guessing the expectation is that one is able to demonstrate how the onboarding/evaluation/off-boarding process itself allows one to meet Best Ex obligations?
("Best Ex" being something to be achieved in aggregate, rather than order by order.)
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