FIA EPTA welcomes the opportunity to respond to ESMA Consultation Paper on Review of the MiFID II framework on best execution reports. FIA EPTA would welcome the opportunity to provide further background to ESMA on the issues raised in our response.
FIA EPTA agrees with the proposed change in scope of execution venues i.e. that execution venues for the purpose of the best execution reporting regime for execution venues (RTS 27) should not include ‘market makers’. In our opinion the scope of the reporting regime should be limited to trading venues and SIs. However, FIA EPTA would question the requirement for ‘other liquidity providers’ to remain in the proposed scope. We believe that the scope of execution venues should mirror that of the STO definition of execution venues.