Glossary

A · B · C · D · E · F · I · K · L · M · O · P · R · S · T · W

A

Appropriateness test

A check of a client’s knowledge and experience of a complex product, before a first order in it. Thalvia runs it in the app before a first leveraged note. A client who fails may not buy the notes at all, although the law asks only for a warning. Clause 5.2 · Chapter 4 · see Complex instrument

B

Best execution

A broker’s duty to take all sufficient steps to get each client the best possible result. For a retail client, that means the best total of price and costs. It is a duty to choose and check the executing bank well, not a promise of the last price seen. Clause 7.1 · Chapter 5 · see Order execution policy

Business day

A weekday on which banks are open in both Cyprus and Germany. Thalvia confirms each trade by the end of the first business day after Holmbrecht confirms it. It also checks its records against the banks’ records every business day. Clause 2, “Business Day” · Chapter 8 · see Reconciliation

C

Client account

The client’s record in the app of their money, investments, orders and fees. Dividends and sale money are credited to it, and the €2 fee is taken from it. It is not a bank account: the cash itself sits in bank accounts that Thalvia holds for its clients. Clause 2, “Client Account” · Chapter 7 · see Client money

Client Agreement

The terms every Thalvia client accepts in the app before the first order. The law requires a written agreement with each client, setting out both sides’ main rights and duties. The version in this workbook takes effect on 1 November 2026, in English, Greek and German, each equally valid. Client Agreement, cover · Chapter 1 · see Durable medium

Client money

Cash that Thalvia holds for a client, never as its own: money paid in, sale proceeds and dividends. It sits in bank accounts in Thalvia’s name for its clients, at Holmbrecht and at a bank in Cyprus, apart from Thalvia’s own money. So it never pays Thalvia’s bills. Clause 2, “Client Money” · Chapter 7 · see Client account, Reconciliation

Compensation fund

The Investor Compensation Fund, which pays retail clients when a firm such as Thalvia fails and cannot return their money or investments. It pays 9 in 10 of what is missing, at most €20,000, so €10,000 missing brings €9,000. It never pays for market losses. Schedule 5, paragraph 3 · Chapter 7

Complex instrument

The Client Agreement’s name for the leveraged notes, the one complex product Thalvia offers. Their risks are harder to judge than a share’s, so a client must pass the appropriateness test before a first order in them. Clause 2, “Complex Instrument” · Chapter 4 · see Leveraged note, Appropriateness test

Conflict of interest

A situation where the firm’s own interest pulls against the client’s. Thalvia’s main one is its fee on every order, so it gains when clients trade more. MiFID II makes a firm prevent or manage each conflict, and tell the client only as a last resort. Clause 13.1 · Chapter 8

Corporate action

An event that affects an investment, such as a dividend, a rights issue or a takeover offer. The shares sit in Thalvia’s name, so Thalvia passes on the news and sets a deadline for the client’s decision. A client who misses it loses the right or gets the default option. Clause 2, “Corporate Action” · Chapter 7

Costs and charges statement

The yearly list, sent each January, of every cost the client paid the year before. It also shows how those costs reduced the client’s return. A client who placed 24 orders and held one ETF all year sees €48 for the orders, €20 for the fund and €68 in all. Clause 12.3 · Chapter 6

CySEC

The Cyprus Securities and Exchange Commission, the regulator that licensed Thalvia in March 2026 and supervises it. It wants clients to know what they buy and what it costs, and their assets kept safe if a broker fails. It may ask to see the Client Agreement. Client Agreement, cover · Chapter 1

D

Durable medium

A form the client can store and read again, and that nobody can change. The law lets a client agreement be on paper or on a durable medium. Thalvia emails each client the Client Agreement as a PDF file, because a page in the app alone could be changed. Clause 1.3 · Chapter 1 · see Client Agreement

E

ETF

An exchange-traded fund: a fund whose units trade on an exchange like shares. Thalvia’s ETFs are all set up as UCITS funds, the standard EU fund for the public, so they count as simple products. Before each purchase, the app shows the fund’s costs in euros. Clause 3.2 · Chapter 1 · see Key information document

Executing bank

The bank that carries out each order Thalvia passes on: Holmbrecht Bank AG, in Frankfurt. It also holds the clients’ investments and part of their money. The client never deals with it, and it pays Thalvia nothing. Clause 2, “Executing Bank” · Chapter 1 · see Best execution, Safekeeping

Execution-only

A service that passes on the client’s own orders without advice or checking that the investment suits them. MiFID II allows it only for simple products, such as shares and UCITS ETFs, with a warning. Each order must be the client’s own idea, so app picks “for you” break it. Clause 3.1 · Chapter 4

Execution venue

The Client Agreement’s word for an exchange where Holmbrecht carries out orders: a regulated market in the euro area, as listed in the app. Each one has its own trading hours, order book and opening auction. Clause 2, “Execution Venue” · Chapter 5 · see Opening auction

F

Financial Ombudsman

A public office in Cyprus that settles disputes between financial firms and their clients without a court. A client must complain to Thalvia first, within 6 months of learning of the problem. The client then has 12 months from that complaint to go to the Ombudsman. Schedule 4, paragraph 4 · Chapter 9

I

Inducement

A fee, commission or other benefit that a firm receives from someone other than its client. MiFID II allows one only if it improves the service to the client and is disclosed. Thalvia refuses them all, except a minor non-monetary benefit such as training about a product. Clause 8.3 · Chapter 6 · see Payment for order flow

K

Key information document

A short paper on one ETF or leveraged note, setting out its features, risks and costs. The app shows it before the client buys, in the language of the client’s country: Greek in Cyprus and Greece, German in Germany. A client in Cyprus who chose English gets it in English. Clause 5.4 · Chapter 4

L

Leveraged note

A bank’s promise to pay a multiple of one day’s index move, up or down, which resets each day. It can lose value fast and is made for short-term trading, not saving. If the issuing bank fails, the client may lose everything, and the compensation fund does not pay. Schedule 6, paragraph 3 · Chapter 1 · see Complex instrument, Target market

Limit order

An order that names a price: the most the client will pay, or the least they will accept. If nobody will deal at that price yet, the order waits in the exchange’s order book. It waits for that trading day or up to 90 days, as the client chooses. Clause 2, “Limit Order” · Chapter 5 · see Market order

M

Market order

An order to buy or sell at the best price available when it is executed. The client fixes the number of shares but not the price. Placed at night, it fills at the opening auction price, which may be far from the last price the client saw. Clause 2, “Market Order” · Chapter 5 · see Limit order, Opening auction

MiFID II

The EU directive on markets in financial instruments (Directive 2014/65/EU), which sets the rules for investment firms such as Thalvia. It decides what a broker must do for each client, from client categories to best execution. Its passport lets one licence reach clients across the EU. Clause 4.2 · Chapter 1 · see Passport

O

Opening auction

The process that sets an exchange’s first price of the day. The exchange gathers all the orders that waited overnight and sets one opening price for them. A market order placed at night takes that price, which may differ greatly from the last price the client saw. Clause 6.2 · Chapter 5 · see Market order

Order execution policy

Thalvia’s written rules on how it gets each client the best result: for retail clients, the best total of price and costs. Schedule 1 summarises it and the full text is in the app. The client agrees to it by accepting the Client Agreement. Schedule 1, paragraph 1 · Chapter 5 · see Best execution

P

Passport

The right of a firm licensed in one EU country to serve clients in another. The firm sends a notice to its own regulator, which passes it to the regulator in the clients’ country within one month. Only then may the firm start, as Thalvia did before opening in Germany. Clause 1.1 · Chapter 2 · see MiFID II

Payment for order flow

Money a market maker, a firm trading from its own stock, pays a broker for each client order sent to it. It lets a broker charge little, but pulls orders towards whoever pays instead of the best result. EU law bans it for retail clients, and disclosure cannot save it. Clause 8.3 · Chapter 6 · see Inducement

Professional client

A client the law expects to look after itself, so it gets less protection. A Thalvia client must first pass two of three tests: frequent large trades, a portfolio over €500,000, or a year in finance. A written request, a written warning, a separate statement and Thalvia’s judgement follow. Clause 4.2 · Chapter 3 · see Retail client

R

Reconciliation

Checking a firm’s own records of each client’s money and investments against the records of the banks that hold them. Thalvia does it every business day and corrects any difference at once. Only its records show which client owns what in the one shared account at Holmbrecht. Clause 10.2 · Chapter 7 · see Client money

Retail client

An ordinary client investing their own money, in the category MiFID II protects most. Every Thalvia client starts as retail. The protections include the appropriateness test, best execution on price and costs, alerts on the leveraged notes and the compensation fund. Clause 2, “Retail Client” · Chapter 3 · see Professional client

S

Safekeeping

Keeping clients’ investments safe: the second service on Thalvia’s licence, which it may offer only alongside passing on orders. Thalvia does it through Holmbrecht. The bank holds the investments apart from its own and Thalvia’s, in one account in Thalvia’s name for all its clients. Clause 10.1 · Chapter 2 · see Executing bank

T

Target market

The clients a product is made for, which the bank that issues it decides. Thalvia must follow it. The issuing banks made the leveraged notes for short-term trading, not long-term saving, so Thalvia never advertises them. Schedule 6, paragraph 3 · Chapter 4 · see Leveraged note

Title transfer

Handing ownership of money or investments to a firm as security. MiFID II bans it for retail clients, and clause 10.3 promises that Thalvia will never ask for it. The same clause bars Thalvia and Holmbrecht from using, lending or pledging client investments. Clause 10.3 · Chapter 7

W

Withdrawal button

The “Withdraw from contract here” button in the app, which Cyprus law requires. It lets a client end the Client Agreement free of charge within 14 days of accepting it or, if later, of receiving it by email. Trades already made stand, with their fees. Clause 1.5 · Chapter 4