The London Stock Exchange Group has submitted a response to the questionnaire on MiFID/MiFIR by Markus Ferber MEP.
In our submission we highlight the following key points:
· We support the provision of access to licences to trade/clear financial instruments based on an index/benchmark, the provisions for non-discriminatory access to CCPs/trade feeds and the intention to provide for fungibility and margin offsetting;
· We welcome the proposals for the creation within the MTF category of a new sub-group category of SME Growth Market and support the proposed definition of SME for the purposes of MiFID, although we warn against any reduction in the thresholds;
· We support the proposals to enhance post trade data quality and harmonisation and endorse the work on the Market Model Typography (MMT) that is being undertaken in co-operation with the vendors, FESE and now with ESMA;
· We support the extension of transparency to other asset classes and all venues, although requirements must be appropriately calibrated per asset class as necessary;
· We are concerned that the Commission’s proposed arrangements on third countries will be damaging to existing access to third country business and we suggest that the appropriate approach might be an omnibus Directive on third country issues;
LSEG response to MiFId/MiFIR questionnaire by Markus Ferber MEP(file pdf - 152 KB)