EFAMA has some concerns with ESMA’s clarifications. In the consultation paper (CP), ESMA seems to have a very broad interpretation of the ‘multilateral systems’ definition under MiFID II and states that ‘systems where trading interests can interact but where the execution of transactions is formally undertaken outside the system still qualify as a multilateral system and should be required to seek authorisation’ (paragraph 36). Such an interpretation is too expansive and could capture a number of nonmultilateral systems such as EMS, OMS, instant chats services, which allow for bilateral interactions. In particular, it could also capture buy-side proprietary systems that have been developed to connect to sellside firms directly. These software providers allow for a more efficient information flow which help buyside and sell-side firms to communicate with each other