FIA EPTA appreciates the opportunity to provide feedback to the European Securities and Markets Authority (ESMA) on the consultation on ESMA’s Opinion on the trading venue perimeter. FIA EPTA considers that ESMA’s approach to defining multilateral systems is overly broad and risks creating further confusion and inconsistencies in the application of MiFID II across the Union. FIA EPTA further considers that ESMA’s position risks overlooking the risk of inherently bilateral systems being allowed to operate under the badge of a multilateral venue and risks exposing less sophisticated investors, notably retail investors, to genuine harm from the perspective of best execution.
