EFAMA welcomes ESMA’s Consultation Paper on product governance requirements and specifically on the target market assessment and supports that the details of these requirements are laid out in the form of guidelines rather than Q&A. We agree with ESMA that drafting target market guidelines is an important aspect “for ensuring the common, uniform and consistent application” of the MIFID II product governance requirements, in particular since these rules have the potential to significantly alter the European distribution landscape.

EFAMA supports every efforts made to enhance financial markets regulation which reinforces the stability and the transparency of the financial system.

In that perspective, EFAMA welcomes the opportunity to comment on the ESMA Consultation Paper on RTS specifying the scope of the consolidated tape for non-equity financial instruments. We consider that a consolidate tape (“CT”) is a key positive factor for price formation and transparency.

Prior to replying to the consultation, we wish to make the following general remarks

EFAMA, welcomes the opportunity to comment on the ESMA Discussion Paper (“DP”) on the trading obligation for derivatives under MiFIR.

As a principle, EFAMA supports every effort made to enhance financial market regulation which reinforces the stability of the financial system, of which MiFIR is an important part.

Prior to replying to the consultation, we wish to make the following general remarks.