MiFID II – Pre- and post- trade transparency - QED

Memorandum
MiFID II – Pre- and post-trade transparency
help in making sure that this
actually comes about this time.
Hence, in Ms Swinburne’s view,
we do not need to move too far
from where we already are with
those particular waivers. Most of
the work probably needs to be
done in the implementation
phase.
Ms Swinburne thinks the posttrade
transparency in MiFID I has
been a complete disaster for the
e q u i t i e s m a r k e t s . T h e
transparency requirements and
concept has not been enough.
There was an accepted norm that
when we put MiFID I in place and
the competition increased that the
reporting mechanism would
continue. Obviously, that has not
been the case for equities.
Reporting trades to a venue not
specifying how or where they
need to go and what the purpose
of that is did not seem to have
been enough. Certainly, the
market has not come forward with
a consolidated tape equivalent.
Ms Swinburne is concerned that
we need to find a solution here.
The Commission has come
forward with a competitive
situation where we have the
competing APAs and we have
consolidated tape providers that
on a competitive basis can put an
offer out there. Ms Swinburne is
prepared to see that this could
work. Her preferred option would,
nonetheless, be to go straight for
a s i n g l e m a n d a t e d t a p e .
Unfortunately there is not a
majority for that in the European
Parliament. In order to get this to
work, the consolidated tape
providers must be required to
collect the data from all the APAs.
Otherwise, if they were to select
only a few of them there would
not be a consolidated tape
equivalent. Therefore, we have to
make sure that we end up with a
tape that is worthwhile, i.e. a
source of data in standardised
form that can be used. In
particular, this tape should be able
to be used by the buy-side to
actually determine whether or not
they are getting best execution