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Q8: Do you agree data should be provided by all the execution venues as set out infootnote 24? If not, please state why not.Q9: If you think that the different types of venues should not publish exactly the samedata, please specify how the data should be adapted in each case, and the reasonsfor each adjustment.Q10: Should the data publication obligation apply to every financial instrument tradedon the execution venue? Alternatively, should there be a minimum threshold ofactivity and, if so, how should it be defined (for example, frequency of trades,number of trades, turnover etc.)?Q11: How often should all execution data be published by trading venues? Is the minimumrequirement specified in MiFID II sufficient, or should this frequency be increased?Is it reasonable or beneficial to require publication on a monthly basisand is it possible to reliably estimate the marginal cost of increased frequency?Q12: Please provide an estimate of the cost of the necessary IT development for theproduction and the publication of such reporting.General principles10. ESMA considers that, in order to be most useful to market participants, the data to be provided byvenues should be:i.ii.iii.precisely defined;published in some standardised format and be comparable between venues; andappropriate for investment firms already using the venue and for those considering doing so.11. In considering these three general principles, ESMA recognises that there are several existing constraintswhich are relevant to each. First, precise definitions must take into account the full range ofinstruments, market microstructures and potential measures of execution quality which are coveredby the best execution obligation. Secondly, the standardisation of format (and, equally importantly, oftiming) which would support full comparability between venues is required, at least initially, withouta consolidated tape. Thirdly, a balance is required between prescriptive data obligations or benchmarksand those which facilitate individual analysis by market participants acting on their own initiativeusing proprietary methodologies.12. Respondents to CESR’s 2009 questionnaire on Best Execution 28 noted several difficulties in monitoringexecution quality. These difficulties included: a lack of transparency or consistency of data; inconsistencyin price improvement calculations; a lack of a standardised cross-market price benchmark (aEuropean Best Bid and Offer, EBBO); and a lack of Volume Weighted Average Price (VWAP). One ofthe principal aims of this Discussion Paper is to address these difficulties by evaluating the options fordata harmonisation, the range of available metrics and the benefits of aligning the monitoring of bestexecution with other standardised reporting obligations.28http://www.esma.europa.eu/system/files/10_1415.pdf27