This is a timely and necessary review to which we hope to contribute in a constructive manner. As already recognised in the consultation paper and in the MiFID Quick Fix proposal, RTS 27 and RTS 28 currently fall short of the objective of providing valuable and comparable datasets for investment managers and the investing public. We appreciate the present effort to revise reporting requirements to produce more meaningful reports.
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.
The Joint Associations1 welcome clarification from ESMA that national competent authorities are expected not to prioritise supervisory actions in relation to the application of the CSDR buy-in regime.2
Joint Statement on EU Commission proposal for revised Market in Financial Instrument Regulation (MiFIR)
We see great value in the creation of a consolidated tape to support Europe’s capital markets. However, we qualify that statement with a reminder that the framework for a successful consolidated tape should
i) address the known market failure around market data costs,
Buy-side experts worried that mandatory active accounts for EU clearing could increase systemic risks, not lower them
EFAMA is pleased to share the link to the educational webinar it organised on 14 June with leading buy-side clearing experts, including Allianz Global Investors, Aviva Investors, BlackRock and Nordea Asset Management, to discuss the main findings of EFAMA's recent analysis on mandated active accounts for EU clearing.
European asset managers continue to urge policymakers to support the European Parliament’s proposal for an Equities/ETFs consolidated tape which includes 5 layers of real-time pre-trade data. Market participants, including the European buy and sell-sides have consistently maintained that a post-trade only equities/ETFs consolidated tape will not meet with the market demand required to make the tape commercially viable. Tanguy van de Werve, Director General of EFAMA, stated: “This would
EFAMA welcomes the recent proposal by European exchanges to build a consolidated tape. This affirms the buy-side’s long standing view that a European consolidated tape is key to completing the objectives of the Capital Markets Union and ensuring that European capital markets remain globally competitive.
A real-time consolidated tape, provided it is made available at a reasonable cost, will bring many benefits to European capital markets. A complete and consistent view of market-wide prices and trading volumes is necessary for any market, though this is especially true for the EU where trading is fragmented across a large number of trading venues.
The current lack of quality pre- and post-trade data and the fragmentation of data sources remain an obstacle to the completion of the Capital Markets Union. The benefits of a real-time Consolidated Tape are wide-ranging: from market surveillance for supervisors, to best execution and an improved view on trading opportunities for retail investors, to portfolio management and pre- and post-trade analysis for fund managers to name a few.
Q #1 How was Euribor impacted by the adoption of the Benchmark Regulation (BMR) and what are the relevant features of the reformed Euribor for investment managers?