EFAMA supports achieving greater transparency through reform of the bond deferral regime. We would like to offer some feedback that suggests a different calibration on both liquidity thresholds, and the determination of trade size buckets.
We appreciate the analysis carried out by ESMA, which offers a solid basis for the review of the bond deferral regime. Nevertheless, we would like to provide some feedback on the proposed approach, which we believe can be further finetuned: