The Markets in Financial Instruments Directive (MiFID) is a cornerstone of EU financial services legislation and is of direct relevance to asset management companies. In 2014, the European Commission adopted new rules revising MiFID, consisting of a Directive (MiFID II) and a regulation (MiFIR). Overall, MiFID II yielded positive results in terms of liquidity and transparency for investors.
Among possible improvements to the MiFID framework, EFAMA encourages the creation of a well-structured, reasonably priced consolidated tape managed by ESMA and fed by all trading venues and systematic internalisers for all financial instruments. A second, long-term EFAMA objective is better enforcement of data providers’ existing obligation to provide market data on a “reasonable commercial basis”.
We see great value in the creation of a consolidated tape to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should
i) address the known market failure around market data costs,
EFAMA is pleased to read today the details of a robust MiFIR proposal from the European Commission addressing key areas of reform around the creation of a consolidated tape (CT), along with adjustments to transparency requirements on trading.
Well-functioning and liquid capital markets are fostered by an efficient market structure and supporting legislative frameworks. A diverse and efficient market structure reduces the costs of trading whilst promoting best execution. This optimises funding opportunities for issuers and maximises returns for investors and savers.
The MiFID/MiFIR review will be key to the future success and competitiveness of the EU's capital markets.
With international competition for investment heating up markedly, European legislators need to ensure that EU regulation is helping, and not hindering, capital market growth and participation.
Various European trade associations representing EU capital markets, including EFAMA, BVI, EFSA and NSA, have published a letter outlining their main priorities for the review. This includes the following core elements:
EFAMA members are paying close attention to the ongoing discussions in the European Parliament and Council to reach a compromise on the MiFID review. Together with a broad majority of market participants, including the sell-side and alternative trading venues, we have consistently made the case for a real-time tape for equities with the inclusion of pre and post-trade data.
EFAMA is appreciative of the opportunity to comment on this major IOSCO study on the dynamics of bond market liquidity during market stresses. We provide some detailed responses below, but would reiterate a few high-level points here:
