EVIA Responds to ESMA CP Development of Prices for Pre-/Post-trade Data & a CTP for Equity Instruments
  • “EVIA calls for Open Access in response to ESMA over high prices for market data”
    • “… more competition for listed exchanges will lead to lower costs. We therefore champion MiFID2’s provisions on Open Access to Market Infrastructures (article 35/36 MiFIR) and are looking forward to the expected benefits which Open Access for exchange traded derivatives will bring from the legislative application date of June 2020 onwards.”
  • On Data Availability:
    • “Market structure matters, fungible instruments and open access to infrastructures facilitate a competitive environment that drives the difference between exchanges and non-exchanges across trading venues”
    • “It is important to distinguish the supply of MIFID2 transparency related services and the data business that provides indicative data and derived value-added services.  The two services can coexist and be regulated differently to empower both transparency and innovation.”
    • “EVIA member trading venues do not charge any member, participant, APA, or post-trade infrastructure for data provision fulfilling any MiFID2/MiFIR transparency requirements.”
  • On CTP:
    • “We urge policy makers to consider the use case for a consolidated tape and not to treat non-equity markets the same as those being directly considered here. Retail requirements are very different to wholesale markets and there are lessons to be learnt from experiences in the United States.
    • “Derivatives will require a very different approach to bonds and equities, likely based on the relevant core-economic-terms and the pre-trade transparency”

 Full response paper is at: EVIA Responds to ESMA CP Development of Prices for Pre-/Post-trade Data & a CTP for Equity Instruments

 

Published: 12/09/2019
Updated: 16:48 on 12/09/2019