12.II.5.1 Verification process

MiFID I required any publication arrangement (i.e. RM, MTF, third party, or proprietary arrangements) ‘to take all reasonable steps necessary to ensure that the information to be published was reliable, monitored continuously for errors, and corrected as soon as errors were detected’.1 MiFID I did not specify what this meant. It was CESR’s view that ‘all reasonable steps’ needed to include a verification process. CESR noted that the verification process was not required to be external from the organization of the RM, MTF or investment firm operating outside such venues, all being subject to MiFID I equity transparency rules. CESR added that any publication arrangement making the MiFID I pre- and post-trade information public needed to be capable of identifying at least price and volume anomalies in the publication process. The chosen process could be reasonable and proportionate in relation to the business.2