The European Commission’s proposal on MiFIR establishes the blueprint for a consolidated tape (CT) for Europe’s capital markets. It also significantly alters the competitive market structure brought about by MiFID II by introducing greater transparency requirements. Finally, it addresses important issues around market data costs.
Investment managers, acting on behalf of their retail and institutional clients, are among the largest investors in financial markets. They represent a key component of the market’s “buy-side” segment.
In representing the interests of its members on wholesale capital market issues, EFAMA advocates for fair, deep, liquid, and transparent capital markets, supported by properly regulated and supervised market infrastructure.
We commend the work that IOSCO has undertaken to date on this topic including the survey work and the summary findings in the form of the report currently under review. It is fair to say that the conclusions of the report and areas for further work gave rise to detailed discussions within our industry, yielding ultimately firm views on the priority areas that we support and see value in, and areas we felt were not reflected in the study and thereby building risk into margining models in future crisis scenari
For asset managers the main issue continues to be the reclassification of ETDs as OTCs as a result of the non-equivalence of UK regulated markets. While we understand that a review is legally mandated at this point in time, we do not see value in recalibrating the various thresholds or making changes to the calculation methodologies unless these are in the two areas we define below. Our main concern revolves around the fact that changes would carry significant compliance costs while making little impact on the population of counterparties and notional captured by the thresholds.
Following the publication of the European Commission report confirming the settlement discipline regime will be reviewed, Susan Yavari, Regulatory Affairs Adviser at EFAMA, commented:
Q #1 When will LIBOR phase out and which rates will be replacing it?
The appropriate construction, and conditions for the usage, of a Consolidated Tape
EFAMA has reviewed ESMA’s statement “Supervisory work on potential index tracking”, which sets out research to determine whether any indication of closet indexing could be found at EU level. To contribute to the debate on this matter, EFAMA has prepared a paper, which highlights the limits of identifying closet index funds through a statistical analysis, drawing on recently published research papers.