9.II.1.5.5 Publication of the RM or MTF market identifier code

MiFID II ‘only’ requires RMs and MTFs to publish the market identifier code (MIC) of the RM or MTF in question. MiFID II does not require the identity of parties to a transaction taking place through the RM or MTF systems to be disclosed. The MiFID II rule is legacy of MiFID I. In drafting MiFID I, CESR noted that post-trade data needs to be published in order to provided sufficient data for ‘identifying trends on the market, checking the quality of completed trades and assisting intermediaries in assessing which trading venues consistently offer the most competitive prices’.1 According to CESR, trends on the market could also be observed without publishing the identity of parties to a transaction. Not less important, the publication of parties to a transaction can harm the position of the traders to the transaction (e.g. increased position risks). Along similar lines, CESR did not propose to publish the identity of the individual parties to a trade. The latter was evident in the final MiFID I text. MiFID II takes a similar approach. The MiFID II equity post-trade transparency regime for RMs and MTFs only requires the publication of the MIC of the RM or MTF.2