Best execution policy

BEST EXECUTION POLICY

INTRODUCTION
Delphi Delta Investment Corporation ("the Company") provides cryptocurrency margin trading and execution services as a U.S.-domiciled corporation organized under New York law, with principal office at 120 Wall Street, New York, NY 10005. The Company operates in compliance with SEC Regulation NMS (17 CFR § 242.600 et seq.), CFTC execution standards for digital asset derivatives, and FINRA best execution obligations (FINRA Rule 5310).

PURPOSE
This Best Execution Policy establishes the Company's commitment to executing client cryptocurrency orders in a manner designed to obtain the optimal available price, considering total cost, speed, likelihood of execution, and settlement reliability. The policy applies to all retail and institutional clients accessing margin trading in digital assets.

The Company acts on an execution-only basis and does not provide investment advice. Best execution obligations arise from principal-to-principal CFD-style crypto derivative transactions executed through the Company's proprietary platform.

EXECUTION FACTORS
When executing client orders, the Company prioritizes the following factors in descending order of importance:

(A) Price: Optimal bid/ask spread reflecting aggregated liquidity from top-tier cryptocurrency exchanges

(B) Speed of Execution: Sub-second execution during normal market conditions
(C) Likelihood of Execution/Settlement: High probability of fills without partial execution or cancellation
(D) Size: Pro-rata allocation for large orders across multiple liquidity venues
(E) Total Consideration: Spreads + commissions + slippage + financing costs

For retail clients, price has highest priority. For large institutional orders (>1M USD notional), size and likelihood of execution may take precedence.

EXECUTION VENUES AND LIQUIDITY SOURCES
The Company aggregates real-time pricing and liquidity from multiple premier cryptocurrency venues including:

"Centralized exchanges" : Coinbase, Kraken, Gemini (regulated U.S. venues prioritized)
Institutional OTC desks and algorithmic liquidity providers
Company proprietary internalization engine (when providing best price)
Dark pool and RFQ mechanisms for large block trades

Venue selection considers regulatory status, execution quality, settlement reliability, and counterparty creditworthiness. No single venue dependence exceeds 30% of total execution flow.

ORDER EXECUTION CRITERIA
(A) Market Orders: Executed immediately at best available aggregated bid/ask
(B) Limit Orders: Filled only at or better than specified price
(C) Stop Orders: Triggered at stop price, executed as market order
(D) Algorithmic Orders: TWAP, VWAP, iceberg execution available for large orders

During Abnormal Market Conditions (flash crashes >10%, exchange outages, extreme volatility >100% daily), execution priority shifts to likelihood of execution and settlement certainty.

ORDER MANAGEMENT SYSTEM (OMS)
Proprietary OMS features:
Smart order routing across 12+ liquidity venues
Pre-trade liquidity checks and price improvement opportunities
Post-trade TCA (Transaction Cost Analysis) reporting
FIFO queue management with no payment for order flow

No third-party payment for order flow (PFOF) arrangements exist. All execution decisions algorithmically determined per policy parameters.

NON-PRINCIPAL CROSSING AND INTERNALIZATION
When Company takes opposite side of client trade (principal execution):
Fills at equal-to or better-than external best bid/offer
Price improvement instances logged and reported quarterly
No front-running of client orders

TRANSPARENCY AND REPORTING
Clients receive monthly execution quality reports including:
Average spreads vs. venue benchmarks
Slippage statistics by asset and size
Execution venue breakdown (% volume)
Price improvement metrics

Annual public Best Execution Statement published per SEC/CFTC requirements.

CLIENT ORDER HANDLING
(A) Timely Execution: Market orders executed within 1 second (99.9% SLA)
(B) No Material Delay: Large orders split across venues if needed
(C) Confirmation: Real-time fills with execution venue disclosure

EXCEPTIONS AND LIMITATIONS
Company may deviate from best price under:
Client-specific instructions (e.g., venue preference)
Minimum size thresholds for certain assets
Abnormal Market Conditions declaration
Regulatory holds (OFAC, SAR filing)

MONITORING AND REVIEW
Compliance Department conducts:
Daily execution quality monitoring
Monthly TCA reviews
Quarterly venue performance assessment
Annual policy review with Senior Management approval

CLIENT RIGHTS
Clients may:
Request execution data for specific orders
Opt for direct exchange routing (additional fees apply)
Terminate relationship if execution materially fails policy standards

AMENDMENTS
Company reserves right to amend policy with 10 days' notice via platform notification. Continued trading constitutes acceptance.