Following the EFAMA's partial response to the European Commission's targeted consultation on the regime applicable to the use of benchmarks administered in a third country, we would like to make additional comments on the ongoing review of the regime.
In our response to ESMA on its review of the guidelines on stress-testing parameters for Money Market Funds (MMFs), EFAMA cautions against using overly simplistic assumptions.
In a letter to policymakers, 18 European buy-side firms state that only an Equities/ETFs tape that delivers data in real-time and that includes pre-trade data in the form of 5 layers of best bid and offer, will meet with the necessary market demand to make the Equities/ETFs Consolidated Tape commercially viable. A reasonably priced tape is also a precondition for success, they argue.
EFAMA comments the European Commission's ViDA Proposal and welcomes the consistency of the proposal and the fact that VAT-exempt services will not be covered by the new DDR. With this solution, the proposal should allow tax authorities to focus on the real risk of tax fraud cases and should not create new burdensome procedures/compliance obligations that would represent new costs that in the end would be imposed on clients/consumers (e.g. end investors) for no reason.
