On March 8, MFA and AIMA submitted a joint letter to the UK FCA regarding the implementation of MiFID II.
Among other issues, in our response, we encourage the FCA to:
- Implement the MiFID II requirement on non-discriminatory access to Organised Trading Facilities (OTFs) and Multilateral Trading Facilities (MTFs) in such a way that eliminates current barriers to access;
- Calibrate and transpose pre- and post-trade transparency requirements in a manner that advances the MiFID II goal of furthering market transparency while maintaining liquidity;
- Clarify that MiFID II transaction reporting requirements do not apply to Alternative Investment Fund Managers (AIFMs) or managers of Undertakings for Collective Investment in Transferable Securities (UCITS); and,
- Ensure that additional regulatory safeguards are put in place to protect confidential transaction data.
