FIA EPTA supports transparent, robust, and safe markets with a level playing field and appropriate regulation for market participants. We consistently support the aim of the market structure reforms laid out in MiFID II/MiFIR and welcome the opportunity to respond to this consultation on MiFID II/ MiFIR review on the functioning of Organised Trading Facilities (OTF).
Our members are aware of various systems and market practices which seem to conflict with MiFID II expectations for multilateral systems. Some of these systems are in fact multilateral but claim not to be. Others, by contrast, claim to be multilateral but act as de-facto bilateral systems. In both cases, this distorts the level playing field and we note that in some cases these systems also raise non-discriminatory access and investor protection concerns. We would strongly welcome regulatory and supervisory convergence measures by ESMA in relation to such systems in order maintain the level playing field in European financial markets.
