Best Execution Policy: Cash Funds – UK Money Markets


This document sets out CCLA’s Order Execution Policy and approach to providing ‘best execution’ for the Cash Funds and Segregated Clients (‘Cash Funds’) managed by CCLA IM and FM on behalf of its clients. For the purpose of this policy, the term ‘client’ will also be used to mean ‘scheme’ or ‘prospectus’ and are therefore deemed to be professional.

When placing deposits with banks and building societies it is not feasible to adhere to the Best Execution Policy for quoted securities. This is principally because transactions in money market instruments are made over the counter on a Trading Facility or with an Execution Venue and are usually indicative. It’s only at the point of agreement between the seller, usually the issuer, and the purchaser is the transaction is binding. In some but not all occasions, a broker is used as an intermediary between the issuer and the purchaser on a Trading Facility.

Under the EU Money Market Fund Regulation 2017/1131, the COIF Charities Deposit Fund is categorised as a short-term LVNAV Money Market Fund.

The Public Sector Deposit Fund is a UK short-term LVNAV Qualifying Money Market Fund.

Eligible financial instruments

When applying best execution obligations, CCLA takes into account the different circumstances surrounding the execution of orders for particular types of financial instruments. Eligible financial instruments comprise of transferable securities (e.g. equities & bonds), money market instruments (e.g. certificates of deposit), units in regulated collective investment schemes, options, futures and other financial derivatives.

For clarity, eligible financial instruments do not include cash accounts, money market deposits, direct property and unregulated collective investment schemes.

Execution venues

Execution venues are the centres through which securities transactions are ultimately facilitated. These include the major Regulated Markets, Multilateral Trading Facilities (MTF), Organised Trading Facilities (OTF), Systematic Internalisers (a firm that deals on its own account), the UK Money Market, third-party investment firms (brokers acting as market makers or other liquidity providers) and the managers of Collective Investment Schemes.

CCLA is not a direct member of a Regulated Market or a Multilateral Trading Facility and uses approved brokers to transact on its behalf or deals directly with its approved deposit takers (in the case of most money market instruments). CCLA’s approved brokers are deemed to operate an OTF or MTF and the approved deposit takers are deemed to be the Execution Venues for the purpose of this Policy.

Remuneration, discounts or non-monetary benefits are not received by CCLA for routing client orders to a particular execution venue.

On an annual basis CCLA will publish the top five brokers in terms of trading volumes chosen for execution. This will be provided for each class of financial instruments and will include a summary on the quality of execution obtained.

CCLA’s list of approved brokers and deposit takers can be found at the end of this policy.

Types of UK money markets

Our funds will typically use money market deposits which include, but are not limited to, Call Accounts, Notice Accounts, Fixed Term Deposits and Certificates of Deposit.

Method of execution

Having assessed the relevant factors and any specific instruction provided by a client, CCLA will select the most appropriate venue(s) from those available and execute the order accordingly.

Best execution policy

After satisfying the Fund’s primary and secondary objectives of security and liquidity respectively, price (or yield) will be the most important execution factor when making a choice between Execution Venues. Other factors including likelihood of settlement, diversification of issuer, and size of ticket will also be a consideration.

When placing a deposit with an issuer CCLA aims to achieve the best price possible (i.e. highest yield) relative to other issuers of similar credit quality and for the same instrument type and period. To achieve this CCLA receives daily indications of issuer yields for different instruments and periods from a number of sources including brokers and directly from issuers. CCLA also maintains a sufficiently long list of approved issuers in order to ensure flexibility to deal with a number of potential issuers.

When selling Certificates of Deposit in the secondary market the same principles will apply although the best possible price will be the lowest yield and significant consideration will be given to market illiquidity.

Where CCLA transmits an order to an approved broker for execution it will look to use its experience in order to improve the terms on which it transacts in that market. CCLA looks to use the execution venue best placed to help the firm add value to any transactions. CCLA does not pay commission on its money market deposit transactions to trading and execution venues.

Monitoring and review of the best execution policy

CCLA will review the policy at least annually and whenever a material change occurs that affects CCLA’s ability to continue to obtain the best possible result for the execution of client orders. Updated versions of this document will be posted on our website (


Approved deposit takers (execution venues)

ABN Amro Bank N.V.

Australia and New Zealand Banking Group Limited

Bank Nederlandse Gemeenten (BNG)

Bank of America N.A.

Bank of Montreal

Bank of New York Mellon (The)

Bank of Nova Scotia (The)

Bank of Scotland plc

Barclays Bank UK plc

Barclays Bank plc

Bayerische Landesbank

BNP Paribas

Canadian Imperial Bank of Commerce

Citibank N.A.

Commonwealth Bank of Australia

Coventry Building Society

Credit Agricole Corporate and Investment Bank

Credit Industriel et Commercial

Danske Bank AS

DBS Bank Limited


Deutsche Zentral-Genossenschaftsbank (DZ Bank AG)

Government of the United Kingdom

Handelsbanken plc

HSBC UK Bank plc

HSBC Bank plc

ING Bank N.V.

JP Morgan Chase Bank N.A.

KBC Bank N.V.

Landesbank Baden-Wuerttemberg

Landesbank Hessen-Thueringen Girozentrale

Leeds Building Society

Lloyds Bank plc

Lloyds Bank Corporate Markets plc

Mizuho Bank


National Australia Bank Limited

National Bank of Canada

Nationwide Building Society

NatWest Bank plc

NatWest Markets plc

Nordea Bank AB

Overseas-Chinese Banking Corporation


Royal Bank of Canada

Santander UK plc

Skandinaviska Enskilda Banken AB

Societe Generale

Standard Chartered Bank plc


SMBC Bank International

Toronto-Dominion Bank (The)


United Overseas Bank Limited

Westpac Banking Corporation

Yorkshire Building Society


Approved brokers (on OTF or MTF)


ICAP Securities Limited

RP Martin a division of BGC


Tullett Prebon Securities


December 2020



Terms and conditions

Website terms of use policy

CCLA Website Terms of Use

Welcome to CCLA's website for:

  • fund management services for  CCLA Funds (details of and documentation relating to all CCLA Funds is available on CCLA’s website); and
  • discretionary investment management services for individual client portfolios.

This page provides you with information about CCLA and the legal terms and conditions (Terms of Use or Terms) on which you can access and use this website.

By using or accessing any part of this website, you confirm that you accept these Terms of Use and that you agree to comply with them.  Please read these Terms of Use carefully and make sure that you understand them before using this website. If you do not wish to be bound by these Terms you must not use or access this website.

Where necessary, we may amend these Terms of Use from time to time by updating this page.  We therefore recommend that you check this page periodically to ensure that you understand the Terms which will apply from time to time.

1. About us (CCLA)

1.1 Any reference to CCLA or we/us on this website (including these Terms of Use) means CCLA Investment Management Limited and/or CCLA Fund Managers Limited (as applicable).

1.2 CCLA Investment Management Limited (CCLA IM) is a company registered in England and Wales with company number 2183088. It is authorised and regulated by the Financial Conduct Authority under the Financial Services and Markets Act 2000 (FSMA), and is entered on the Financial Services Register under registration number 119281.

1.3 CCLA Fund Managers Limited (CCLA FM) is a company registered in England and Wales with company number 8735639.It is authorised and regulated by the Financial Conduct Authority under FSMA and is entered on the Financial Services Register under registration number 611707.

1.4  The registered office of CCLA IM and CCLA FM is Senator House, 85 Queen Victoria Street, London, EC4V 4ET.You may also contact CCLA by emailing

2. Who may use this website

2.1 The information on this website is intended for investors and prospective investors in the CCLA Funds and or clients or prospective clients of CCLA's services. Only certain types of investor are eligible to invest in the CCLA Funds (in summary these are charities and local authorities and certain of the CCLA Funds are restricted to particular types of these investors).

  • Charities for these purposes are charities or charitable organisations registered with the Charity Commission of England and Wales, or charities exempt from registration, or other persons eligible to participate in collective investment schemes constituted under the Church Funds Investment Measure 1958, section 24 of the Charities Act 1993 (now amended to section 96 of the Charities Act 2011), or section 25 of the Charities Act 1993 (now amended to 100 of the Charities Act 2011), or equivalent organisations in Scotland or Northern Ireland.
  • Local authorities for these purposes are local authorities as defined in section 23 of the Local Government Act 2003.

2.2 Please ensure that you understand whether or not you are an eligible investor in respect of the CCLA Funds, investments and investment services referred to on this website.

3. The purpose of this website

3.1 This website is for information purposes only and is intended as a general introduction to CCLA and the Funds it manages and/or provides investment management services to. The website content and any products and/or services described within it are subject to change without notice.

3.2 Nothing contained on this website constitutes the provision of investment, tax, legal or other advice. This website should not be regarded as constituting a distribution or an offer or solicitation to sell shares or units in any of the funds managed by CCLA outside the UK. Any opinions expressed on individual funds, services or products represent our views at the time of preparation and should not be interpreted as a personal recommendation to buy or sell any of the investments that may be referred to.

3.3 In using this website you may navigate between different pages which relate to different Funds. Each webpage will clearly identify the Fund to which it relates and bespoke information presented on each webpage will relate to the identified Fund.

4. Risk warning

4.1 The value of the CCLA Funds’ units and/or shares and the income from them can fall as well as rise and an investor may not get back the amount originally invested. Past performance is no guarantee of future returns.

4.2 Please refer to the Funds’ individual scheme particulars or prospectus for an overview of the investment risks identified by CCLA and the applicable terms and conditions for investing in the Funds, including rules concerning when sums invested may be realised by the investor. Any estimates of future capital or income returns or details of past performance on this website are for information purposes and are not to be relied on as a guide to future performance.

4.3 Persons who do not have professional experience in matters relating to investments are strongly encouraged to consult with a financial adviser before making any investment decision.

5. Complaints and compensation

8.1  All complaints will be handled in accordance with CCLA’s Complaints Policy  which can be found at

 If either CCLA IM or CCLA FM cannot meet its obligations (for example, where it has stopped trading and there are insufficient assets to meet its obligations), investors may be eligible to claim compensation up to a maximum of £85,000 from the Financial Services Compensation Scheme. There are limits on who is eligible to claim and which funds are covered. For further information about the Financial Services Compensation Scheme please refer to or phone 0800 678 1100.

6. CCLA's liability

6.1 We give no warranty or representation and accept no liability for the accuracy, completeness or appropriateness of the information and material available on this website. Your use of any information or materials is entirely at your own risk and we accept no liability for any damage or loss including loss of profit whether direct, indirect or consequential in respect of the use of this website or its content; however, we do not exclude or restrict any liability that we may have under FSMA.

6.2 Due to the nature of the Internet, errors, interruptions and delays may occur at any time. Accordingly, this website is provided on an "AS IS" and "AS AVAILABLE" basis without any warranties of any kind. We shall have no liability, contingent or otherwise, or any responsibility whatsoever, for any interruption in availability of this website regardless of whether the connection or communication service is provided by CCLA or a third party service provider.

6.3 Transmission of information via the Internet is not completely secure and we cannot guarantee the security of your data transmitted to this website. Any transmission is at your own risk. We will use strict procedures and security features to try to prevent unauthorised access and we will do our best to protect your information (including personal data). However, we accept no liability in the unlikely event of a breach of our secure computer servers.

6.4 We will use reasonable endeavours to ensure that this website does not contain or promulgate any viruses or other malicious code. However, it is recommended that you should virus check all materials downloaded from this website. We will not be liable for any viruses, code, files or programs designed to interrupt, restrict, destroy or otherwise compromise the integrity of the website or any hardware on which it is hosted. We exclude to the fullest extent permitted by applicable laws all liability in connection with any damage or loss caused by computer viruses or other malicious code originating or contracted from this website.

7. Third party websites

7.1 This website may provide links to certain websites sponsored and maintained by third parties. CCLA is not responsible for the accuracy of information contained within websites provided by third parties and makes no representations concerning the content of such third party websites. The fact that CCLA may provide a link to another website does not constitute an endorsement, authorisation, sponsorship, or affiliation by CCLA with respect to that website, its owners, or its providers. You will be responsible for complying with the terms and conditions of use for any linked website.

8. Copyright and trade marks

8.1 CCLA is the owner or the licensee of all intellectual property rights in this website, and in the material published on it. Those works are protected by copyright laws and treaties around the world. All such rights are reserved.

8.2 You must not use any part of the materials on this website for commercial purposes without obtaining a licence to do so from us or our licensors.

8.3 No use of CCLA's name, logos and/or other trademarks (whether registered or unregistered) may be made by you without separate express written agreement being given by us, which shall be at our sole discretion.

9. Data protection

9.1 We will hold any personal information that you may provide to us through our CCLA website in confidence and in accordance with CCLA’s Privacy Notice and current Data Protection Legislation. CCLA is the data controller of any such information for these purposes.

9.2 You agree that the CCLA may process your personal data to: (i) confirm your identity and carry out background checks (which may involve sharing your personal data with third parties such as credit reference agencies); (ii) provide our services to you; (iii) follow up with you after you request information; (iv) comply with any requirement of any applicable statute, regulation, Financial Conduct Authority Rule and good practice and to fulfil our obligations under any reporting agreement entered into with any tax authority or revenue service(s); (v) prevent and detect abuse of our services or any of our rights and to protect our (and others’) property and rights; (vi) contact you by post, e-mail or telephone to bring to your attention additional products or services which may be of interest to you (you may inform CCLA at any time if you do not want to receive such communications); and (vii) as otherwise agreed by you. Failure to provide the personal data requested (or to agree to the above or below uses) may mean that CCLA is unable to provide the services requested.

9.3 CCLA may pass your personal data to any other firm within CCLA but will not pass on any personal data to any other third party except: (i) where, in relation to the performance of its services to you, CCLA sub-contracts part of the services or any support services; (ii) as agreed by you; or (iii) where required to do so for regulatory purposes as set out above.

9.4 CCLA may in exceptional circumstances transmit and process your personal data outside of the UK  in countries that do not provide the same level of data protection as the UK. In such unusual circumstances, you agree that it may do so subject to CCLA endeavouring to ensure that the arrangements comply with the standards required by the UK Information Commissioner.

9.5 Your use of this website (and your interest in particular webpages or particular CCLA products or services) may be monitored by CCLA. CCLA may keep records of all business transactions for at least five years.

9.6 By accepting these Terms of Use, you agree to the processing and disclosure of personal information as above. You are entitled to request details of information we may hold about you and to require us to correct any inaccuracies in your personal data. CCLA will treat all clients' records as confidential and so reserve the right to provide copies of your particular record, rather than allow access to files which may contain information about other clients. If you wish to access copies of your personal data or ask about the above arrangements, please contact CCLA's Data Protection Adviser at CCLA Investment Management Limited, Senator House, 85 Queen Victoria Street, London, EC4V 4ET.

9.7 Full details of CCLA’s Privacy Notice is available on CCLA’s website. Full details of CCLA’s Data Protection Policy, are available on request.

10. Cookies

10.1 This website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse the website and also allows us to improve the website.

10.2 When you confirm you have read this page we will place a cookie on your computer to recognise you and prevent this page reappearing should you access this website on future occasions. The cookie will expire after six months, or sooner should there be a change to this important information.

10.3 You can activate the setting on your Internet browser to refuse the setting of all or some cookies. However, if you use your Internet browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website. To help us provide a more personalised viewing experience we recommend that you view this website with a JavaScript enabled browser.

10.4 For more information about cookies, including how to set your Internet browser to reject cookies, please visit

11. Recording of communications

 Your telephone calls and electronic communications with CCLA may be recorded. You agree that CCLA may deliver copies or transcripts of such recording to any court or competent regulatory authority.  Such records of conversation and/or communications with you will be available on request for a period of five years (or, where requested by the FCA, for a period of up to seven years) from the date when a record is made.

12. General

12.1 Each of the paragraphs of these Terms of Use operates separately. If any court or relevant authority decides that any of them are unlawful or unenforceable, the remaining paragraphs will remain in full force and effect.

12.2 If we fail to insist that you perform any of your obligations under these Terms of Use, or if we do not enforce our rights against you, or if we delay in doing so, that will not mean that we have waived our rights against you and will not mean that you do not have to comply with those obligations.

12.3 These Terms of Use are governed by English law and are available only in English. You and we both agree that the courts of England and Wales will have non-exclusive jurisdiction over any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with these Terms of Use.

18 August 2021             




Public sector funds

Public sector funds

The Local Authorities Property Fund (“LAPF” or “the fund”) is an unregulated collective investment scheme. As such, only persons who have been assessed as elective professional clients by CCLA in respect of the fund (or are already investors in the fund) are able to access details of the fund on this website.

If you have not been assessed as an elective professional client by CCLA or are not an existing investor in the fund, please contact us to discuss this fund:

Client Services

0800 022 3505

I confirm that I am a local authority/public sector body as defined in section 23 of the Local Government Act 2003. I also confirm that I have been assessed as an elective professional client by CCLA and/or I am an existing investor in the LAPF.