On 6 September, FIA submitted a response to ESMA to their consultation on the development in prices for pre- and post-trade data and on the consolidated tape for equity instruments. The consultation covers the review provisions on the development in prices for pre- and post-trade transparency data from regulated markets, multilateral trading facilities (MTFs), organised trading facilities (OTFs), approved publication arrangements (APAs) and consolidated tape providers (CTPs) as well as the functioning of the consolidated tape (CT) for equity instruments as provided for in Articles 90(1)(g) and 90(2) of MiFID II and Article 52(7) of MiFIR.
FIA’s response focuses on market data fees for exchange-traded derivatives and is limited to the views of FIA primary members (clearing firms). It highlights the increased importance of real-time market data for firms’ regulatory compliance and risk control/mitigation purposes, which makes it mandatory for them to consume essential data from trading venues. It also calls for increased transparency of data fees and more consistency when it comes to billing rules that different trading venues have implemented.