On September 6, MFA and AIMA submitted detailed comments in response to ESMA’s consultation paper: MiFID II/MiFIR review report on the development in prices for pre- and post-trade data and on the consolidated tape for equity instruments.
The Associations supported ESMA’s review and raised concerns that despite the objectives and requirements of MiFID II/MiFIR to lower market data costs and to improve access to accurate, timely market data, fees have continued to increase and some trading venues continue to violate provisions that require post-trade data to be made free of charge after 15 minutes. The Associations recommended that ESMA make clear that market data fees should be tied to the cost of aggregating and producing data and that it should consider switching from a “transparency plus” model to a “cost-plus” methodology.
The Associations encouraged ESMA to take regulatory steps to encourage the development of a consolidated tape as a post-trade consolidated tape would deliver benefits to all market participants. Lastly, we encouraged ESMA to provide guidance to help standardize market data terminology and definitions.
The Associations also sent a copy of the letter to the UK Financial Conduct Authority.