MFA Submits Response to ESMA on Consultation and Discussion Papers on MiFID II and MiFIR

MFA submitted its response to the European Securities and Markets Authority’s (ESMA) consultation and discussion papers regarding the implementation of the Markets in Financial Instruments Directive (MiFID II) and the Markets in Financial Instruments Regulation (MiFIR).

MFA’s comments reflect a commitment to the policy goals of MiFID II/MiFIR – to improve market transparency, to ensure depth and liquidity of markets, and to increase investor protection – while ensuring that the new, suggested rules are consistent and harmonized with those of other major jurisdictions.  Among other important issues, MFA’s responses focused on ESMA’s questions regarding the derivatives trading obligation, straight-through-processing, transparency requirements, the definitions of algorithmic and high frequency trading, position limits, and inducements.