ICMA responds to ESMA's MiFIR review report on the obligations to report transactions and reference data
20 November 2020 On 24 September, the European Securities and Markets Authority (ESMA) published a consultation paper examining transaction reporting and reference data obligations under the Market in Financial Instruments Regulation (MiFIR) (the Consultation Paper). ICMA's response is now available.
ICMA believes that ESMA is trying to reduce overlap between MAR and MiFIR regulations, as well as making better cross-over use of the technology between the market abuse and MiFIR transparency teams. However, ICMA members question whether the benefit of an expanded scope (potentially creating excess unusable data [see paragraph 43 of the consultation paper]) will bring the claimed aims of market resilience, liquidity and efficiency to the financial industry participants. This consultation paper is particularly complex requiring detailed answers. ICMA members focused on questions concerning transparency, market structure impacts, scope of instruments (TOTV) and reference data.