FIA EPTA welcomes the opportunity to respond to the FCA Call for Input on accessing and using wholesale data. Below, we respond to the FCA’s questions in relation to trading data, benchmarks and market data vendor services. FIA EPTA members observe that user data fees are high and have increased over the past years. Empirical data which we have analysed substantiates this. We also observe that new fees have been added and that market data policies and agreements are increasingly complex. In addition, existing rules and disclosures in relation to making certain market data available free of charge and the Reasonable Commercial Basis provisions are not being fully complied with. In order to address these issues, FIA EPTA would encourage the FCA to ensure that existing rules are being complied with and, where needed, enforced. Additionally, we believe more prescriptive rules need to be developed. In our view, increased transparency around market data cost should be the primary near-term goal. We believe it would be premature to look at further regulation of market data (e.g., through price capping) before there is more transparency on the current costs and margins on market data.
