Einde inhoudsopgave
EU Equity pre- and post-trade transparency regulation (LBF vol. 21) 2021/18.IV.2.2.2
18.IV.2.2.2 MiFID I Review: equity pre- and post-trade data
mr. J.E.C. Gulyás, datum 01-02-2021
- Datum
01-02-2021
- Auteur
mr. J.E.C. Gulyás
- JCDI
JCDI:ADS267254:1
- Vakgebied(en)
Financieel recht / Bank- en effectenrecht
Financieel recht / Europees financieel recht
Financiële dienstverlening / Financieel toezicht
Voetnoten
Voetnoten
CESR, Public Consultation: Publication and Consolidation of MiFID Market Transparency Data, October 2006 (CESR/06-551), p. 10-11. The concerns were less pressing in the area of pre-trade data consolidation, since the scope of the MiFID I pre-trade transparency requirements was limited to RMs, MTFs, SIs, and client limit orders outside RMs and MTFs. Instead, the MiFID I post-trade transparency regime applied to a wide range of venues, being RMs, MTFs, and investment firms operating outside RMs and MTFs.
CESR, Public Consultation: Publication and Consolidation of MiFID Market Transparency Data, October 2006 (CESR/06-551), p. 10-11. The concerns were especially pronounced with respect to post-trade information for investment firms using their websites as the publication arrangement when trading outside RMs and MTFs.
CESR, Public Consultation: Publication and Consolidation of MiFID Market Transparency Data, October 2006 (CESR/06-551), p. 10-11.
CESR, Publication and Consolidation of MiFID Market Transparency Data, February 2007(CESR/07-043).
CESR, Publication and Consolidation of MiFID Market Transparency, February 2007(CESR/07-043)(CESR/07-043, p. 3-4.
The MiFID I text, once available in its final form, resulted in all sorts of questions and concerns from the market. A main concern was the consolidation of post-trade data, which could be fragmented across a much wider range of trading platforms compared to the concentrated market setting of the ISD.1 Another concern was the freedom that MiFID I gave to the publication of equity pre- and post-trade data, in particular to investment firms operating outside RMs and MTFs. Especially websites of investment firms operating outside RMs and MTFs could be difficult to read (difficult to consolidate)2 and could harm data quality compared to the experienced RM (and some MTF) publication systems.3 All of these matters were, albeit in a formally non-binding way, addressed by the CESR guidelines and recommendations.4 CESR’s guidance, although formally non-binding (soft law), urged market participants to take the guidance into account when designing or upgrading systems.5