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 the obligations to report transactions and reference data.
FIA EPTA members consider that improvements can and should be made to the existing requirements, targeting simplification and reduction of complexity of the reporting regime while ensuring that OTC derivatives are brought into the MiFID II transparency regime to the fullest extent possible. FIA EPTA members strongly support ESMA extending reference data reporting, transaction reporting, and transparency to include derivatives traded with an SI.
FIA EPTA members strongly encourage ESMA to stipulate that trading venues publish the actual TVTIC in their execution messages to reduce the complexity around TVTIC and improve the data quality of transaction reporting.
