16.III.1 General

MiFID I did not provide a clarification whether a reasonable commercial basis could involve the MiFID I equity pre- and post-trade data to be sold (bundled) with other services and/or other data (e.g. pre- and post-trade data only sold as a ‘package’). The lack of clarification raised questions, for example, whether an investment firm could bundle the sale of its equity pre- and post-trade data with the service of providing financial research.1 CESR provided guidance through formally non-binding guidelines.2