MFA, AIMA, Bundesverband Alternative Investments, BVI (German Investment Funds Association), and the Investment Association submitted a letter to the European Commission thanking its staff for meeting with representatives of the Associations to hear about and discuss access to market data. In our letter, we raised concerns that current practices among EU trading venues in the area of market data undermine the policy goal of building a European data economy and impede the ambition of a digital single market that would benefit a broad range of retail and professional investors. The letter discusses members’ experience with market data licensing agreements and trading venue audits of their market data usage; and raise concerns that trading venues are not complying with the MiFIR requirements to provide data on a reasonable commercial basis.
We recommended that European policymakers:
- Reconsider policy approaches to market data, such as by examining fees relative to revenue or costs;
- Consider how rules could support greater standardization in terms of definitions and other terminology or practices employed by market data licensing agreements;
- Look broadly at similar challenges that arise in respect of index licensing and use of credit ratings; and that
- The European Commission work with US regulators in addressing these issues.
