13 November 2017
Verena Ross
European Securities and Markets Authority
103 Rue de Grenelle
75007 Paris
France
Outstanding uncertainties in the MiFIR post‐trade transparency framework
Dear Verena,
One of the key changes introduced by MiFIR, in particular in the secondary markets area, is the introduction of a pre‐and post‐trade transparency framework for non‐equities trading, both on‐venue and OTC. Whilst MiFIR establishes the groundwork for this framework, it leaves a significant amount of detail to Level 2, and even more interpretive and technical issues to regulatory clarification, for example through Level 3. ISDA, AFME, and GFXD members are aware of the huge task that this has left to regulators, and are grateful for the ongoing clarity that has been and continues to be provided by ESMA and National Competent Authorities (NCAs). The various ESMA Q&A, Opinions and consultations, as well as consultations and industry outreach by NCAs have been extremely useful.
With
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