10.VI Conclusion

The publication of equity pre- and post-trade data can occur by (1) a trading platform itself (e.g. an RM or SI) or (2) a third party (e.g. a data vendor). Equity pre- and post-trade data (whether published by the trading platform itself or a third party) can be made accessible (so-called dissemination) to data users through various technical solutions, including a standard Internet connection or co-location. Published equity pre- and post-trade data enables investors to compare current trading opportunities and completed trades. The comparison is even easier when the equity pre- and post-trade information is (also) consolidated. Consolidation refers to the practice of (i) collecting published equity pre- and/or post-trade data and (ii) making the collected data available in one place. Consolidation can take place through a consolidated tape (post-trade information) and/or consolidated quote (pre-trade information). High quality equity pre- and post-trade data publication (i.e. accurate, timely, and comparable) is essential to set up a consolidated tape or consolidated quote. The optimal amount of consolidation depends on the market setting and market preferences. High quality data publication and consolidation can be achieved through bottom-up or top-down solutions, or a combination of both (hybrid). As will be shown below, the EU has from the ISD to MiFID II shifted towards a more top-down approach for publication and consolidation (i.e. more EU regulation). Several aspects of data publication and consolidation are regulated on the EU level. While doing so, the EU intends to leave room for market forces (bottom-up elements). The EU regime might become more top-down after the MiFID II Review, in particular in relation to the establishment of a consolidated tape and/or consolidated quote.