February 2011

LSEG Response to European Commission Consultation on the Review of MiFID

The London Stock Exchange Group has submitted a full response to the European Commission’s public consultation: “Review of the Markets in Financial Instruments Directive (MiFID)”.

Our submission highlights our key points in respect of the the Review and the issues it raises regarding the effective and efficient operation of the EU financial markets. In summary:

• A harmonised pan-European regime for quoted SMEs must enable Europe’s diverse growth markets to thrive;
• Any changes to regulation, in particular on ‘dark pools’, automated trading or HFT, must be based on strong clear principles and evidence;
• We support moves to improve the quality and consistency of post-trade data. Appropriately regulated multiple consolidators can provide as authoritative a tape as a single provider and this is the Option we support in delivering a consolidated tape;
• We would welcome greater consistency and certainty in the interpretation of pre-trade transparency waivers for equities;
• We are concerned that an excessively strict stance on Third Country Access could damage the EU's competitive position, possibly beyond in financial services;

The Response discusses many of the other issues raised by the Consultation; for more detail, please see the relevant section of the Response:

• Market structure (including  Organised Trading Facilities, broker crossing systems, Tick sizes)
• Pre- and post-trade transparency- (equity-like instruments, Non Equity asset classes & OTC trading)
• Measures specific to Commodity Derivative Markets
• Transaction Reporting
  Investor protection and provision of investment services (including execution only services)       
• Convergence of the regulatory framework
• Reinforcement of supervisory powers

Downloads

LSEG Submission to EC on MiFID Review(file pdf - 1 MB)