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There are alternative available approaches to ensuring that orders of different sizes are renderedcomparable. One is to split trades into ranges by volume or by value so that only those tradesthat are within the same range are compared with one another. A second approach to capturingorder size would be to compare the depth-weighted spread of different venues. A summary ofthese approaches is provided in Section C of the Annex to this chapter.iii. The number of orders executed provides the basis for calculating the ratio of orders executed toorders cancelled.iv.The number of orders cancelled may be another indicator of available liquidity on a venue (if orderswere cancelled because they were left unfilled) or, alternatively, of the presence of high frequencytrading strategies that may influence investment firm or client selection of a venue. Thetime period for order cancellation would need to match the basis for reporting the number of ordersexecuted.25. Responses to CESR’s 2009 questionnaire on Best Execution identified a wide variety of other factorsused by respondents to choose a new execution venue. 29 Clearing and settlement services are also takeninto consideration, including any credit risk from the absence of central clearing.26. In addition, operational risks and venue resilience were identified as potential factors (for example, inthe availability of circuit breakers that operate in periods of market stress). ESMA recognises thatthese qualitative factors are not exhaustive, but also that there is a limit to the information that it maybe appropriate to require in a standardised report.27. Further to your answer to Question 13, and having considered the above execution quality data,please consider the following questions on the scope of the execution quality data publication obligationon execution venues.29http://www.esma.europa.eu/system/files/10_1415.pdf.31

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