MiFID II â Pre- and post- trade transparency - QED
MiFID II â Pre- and post- trade transparency - QED
MiFID II â Pre- and post- trade transparency - QED
Create successful ePaper yourself
Turn your PDF publications into a flip-book with our unique Google optimized e-Paper software.
Memor<strong>and</strong>um<br />
<strong>MiFID</strong> <strong>II</strong> – <strong>Pre</strong>- <strong>and</strong> <strong>post</strong>-<strong>trade</strong> <strong>transparency</strong><br />
some regulatory responsibility.<br />
Hence, from the market’s<br />
perspective, this is the preferred<br />
choice. It will give the best quality<br />
of data <strong>and</strong> the lowest price.<br />
There are concerns that it<br />
p o t e n t i a l l y c o u l d l e a d t o<br />
c o m p l a c e n c y a n d l a c k o f<br />
innovation but a frequent tender<br />
process will keep the vendors on<br />
their toes.<br />
The second choice, which is<br />
workable but, in Mr Cameron’s<br />
opinion, not as optimal is where<br />
the data st<strong>and</strong>ards are set by<br />
ESMA <strong>and</strong> collectors of data can<br />
compete on price, i.e. you allow<br />
pure competition in that area but<br />
y o u d o n o t g e t t h e d a t a<br />
fragmentation. Mr Cameron is,<br />
however, worried about the third<br />
choice, which is letting the market<br />
dictate a solution <strong>and</strong> if it does not<br />
work the regulators will come<br />
back <strong>and</strong> change it. This is better<br />
than nothing but unfortunately<br />
what it means is that the market <br />
will probably not come together<br />
with a solution <strong>and</strong> we then will<br />
have two wait another couple of<br />
years before we have a m<strong>and</strong>ated<br />
solution. <br />
<br />
We have to start looking through<br />
an additional lens on all regulation.<br />
We have to look at various areas<br />
such as the overall health of the<br />
market, how deep is the market,<br />
how useful is the market for<br />
participants <strong>and</strong> we need to look<br />
at cost. Cost is under pressure<br />
everywhere in the entire industry<br />
because of the low growth rates.<br />
Consequently excess cost <strong>and</strong><br />
unneeded cost has been heaped<br />
on an industry, which, at the<br />
moment, is under duress. This is<br />
necessarily not a good thing.<br />
<br />
We also need to look at the<br />
practicality of implementation.<br />
When you look at all the regulation<br />
coming from principally both sides<br />
of the Atlantic, we have an<br />
enormous amount to adhere to as<br />
an industry at the same time. A lot<br />
of those regulations are conflicting<br />
with each other despite the best<br />
efforts of everyone to try to get<br />
them to coordinate. I think the<br />
most important of all is what is the<br />
effect of these regulations in<br />
isolation <strong>and</strong> cumulatively on the
Change language