The World Federation of Exchanges Responds to Europe’s MiFID II Consultation

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The World Federation of Exchanges (“WFE”), the global industry group for exchanges and CCPs, has responded to the European Commission consultation on the review of the MiFID II/MiFIR regulatory framework, representing the global industry’s position on proposals for a consolidated tape in Europe, the Share Trading Obligation’s impact on Third Countries and the regime governing Systematic Internalisers.

Some of the highlights include:

  1. The consolidated tape: The WFE’s position is that a post-trade tape of record represents the only consolidated tape which has a clear use case and would be likely to be viable in terms of costs and benefits.
  2. Market Data: The WFE remains concerned that the consumers of market data are using the prospect of an EU consolidated tape not to further the interests of end-investors, but rather their own commercial interest through regulatory price controls.
  3. The share trading obligation: The WFE’s view is that third-country venues and shares are important to the European financial market value chain. Therefore we suggest a balanced mechanism for excluding them from the share trading obligation, while bringing in EU listings from third-country.
  4. The regime for spot FX: We encourage the European Commission to refrain from making changes to the regime for spot FX in the context of the ongoing implementation of the Global Code.

Nandini Sukumar, Chief Executive Officer, the WFE said: “Europe is an important region. Exchanges and CCPs around the world believe that the market structure being created as a result of MiFID II will influence capital market development around the world. As such it’s important to get it right, especially at a time when we are confronting a global recession and the difficult task of rebuilding economies.”

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