CONSULTATION RESPONSE
x
x
ESMA consultation on RTS 1 & 2 under MiFIR: EBF High level comments
x
BRUSSELS, 30 September 2021 – The EBF would like to thank ESMA for the opportunity to comment on the proposed changes on RTS 1 & 2 under MIFIR.
The EBF would like to share some concerns regarding this consultation on the following:
- Timing: it is highly important to ensure that all amendments are made subject to a thorough cost/benefit analysis and to avoid temporary solutions that may be overhauled by a forthcoming MiFID Review
- Mandate: EBF has some concerns regarding ESMA’s mandate to propose certain changes
- Alignment between MAR and transparency requirements under MIFIR : it is key to clarify that it would be allowed for an investment firm not to publish a transaction under the transparency rules if such publication would be in contravention with MAR
- Streamlining: While we generally support the intention to reduce overlaps and to streamline above mentioned articles, we are not entirely convinced that the some reference are sufficiently unambiguous.
More information:
Pauline Guérin, Senior Policy Adviser, Financing Growth p.guerin@ebf.eu
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post ESMA consultation on RTS 1 & 2 under MiFIR: EBF High level comments appeared first on EBF.
]]>EBF advisor: Pauline Guerin
Publication date: 14 September 2020
BRUSSELS, 14 September 2020 – The European Banking Federation has responded to the European Commission consultation on Research amending delegated directive (EU) 2017/593.
KEY MESSAGES
- EBF fully supports the EU Commission proposal to amend MiFID II delegated Directive (EU) 2017/593 aiming at easing the funding of investment research, in particular on small and mid-cap issuers and on fixed income instruments.
- However, the scope of application of the EC proposal is too limited. It would be appropriate to provide for the extension of the proposal to all companies irrespective of their market capitalisation value. In this direction, EBF urges the EU Commission to put forward a wider proposal to review the investment research regime under MiFID and to introduce any initiative aimed at preventing investment research coverage, in particular on SMEs, decline, taking stock of the results of the public consultation on MiFID II/MiFIR closed in May 2020.
Find the EBF response to this consultation by clicking the ‘full document’ link below:
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post Recovery package: EBF response to EC consultation on research appeared first on EBF.
]]>EBF advisor: Pauline Guerin
Publication date: 4 February 2020
In line with the 2020 European Commission work program, the EBF supports amendments to MIFID and MIFIR requirements.
- The EBF is supportive of further consistency in EU regulation (in particular MIFID, PRIIPS and UCITS). The EBF would also like to stress the need for amendments to be evidence-based and for firms to begiven a sufficiently long implementation period in order to adapt to the new rules. Finally, the EBF supports the need for an overall assessment of MiFID 2/MiFIR to be conducted according to the principle of proportionality.
- Wholesale clients should be exempted from the information requirements in MiFID 2 whilst allowing individual clients to opt down and be treated as retail clients for a particular service or transaction. With specific reference to the disclosure of the costs and charges’ requirements, we believe it would be more balanced to provide a full exemption from the ex-ante disclosure.
- We support the proposal to allow investment firms to provide ex-ante cost information under the same conditions as set out in Article 25 (6) MiFID 2. The article entitles the provision of a suitability report immediately after the transaction under certain conditions and without having to delay the transaction.
- Regarding market structure, we support the improvement of data quality and reporting requirements and would highlight, too, the issue of raising data costs.
Find the EBF response in this consultation by clicking the ‘full document’ link below:
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post German Position Paper on MiFID Review: EBF comments appeared first on EBF.
]]>EBF adviser: Pauline Guérin
Publication date: 12 September 2019
General Comments:
EBF share the view that the costs for market data have increased since the entry into application of MIFID 2.
Despite the directive stressing that the costs of market data should be provided on a reasonable commercial basis, explicitly specified as being based on cost with a reasonable margin, the new requirement hasn’t reached its objective. Overall market data costs and complexity have continued to increase whereas market data transparency and data quality have decreased. The main cost driver for market data users is not so much increase in already existing fees but the introduction of new fees related to multiple display-terminal, non-display applications, reporting and distribution licences, systematic internalisers market data fee, connectivity fees etc. – in combination with unclear and complex market data policies and definitions and unreasonable audit procedures. Additionally, regulatory requirements contribute to the increasing cost of market data. E.g. the Market Abuse Regulation require access to realtime data to ensure proper surveillance.
Thus, the EBF members call for further action from ESMA.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post ESMA consultation cost of Data – EBF response appeared first on EBF.
]]>
Publication date: 21 November 2016
Responding to this paper:
The European Securities and Markets Authority (ESMA) invites responses to the specific questions listed in the ESMA Discussion Paper on the trading obligation for derivatives under MiFIR, published on the ESMA website.
Subscribe to the EBF Weekly + FinReg Agenda
Every Friday at noon you can receive the EBF Weekly + Financial Regulation Agenda. This agenda presents an overview of upcoming European and international meetings and conferences in financial regulation, as well as important general financial and economic events and key EBF meetings for the week ahead. CLICK HERE TO SUBSCRIBE
Subscribe to the EBF Morning Brief
The EBF Morning Brief is published Monday through Friday morning and brings you the top banking headlines, relevant announcements from the EU institutions and the latest from the EBF and its members, national banking associations in 32 countries in Europe. CLICK HERE TO SUBSCRIBE
The post EBF reply to the Discussion Paper on the trading obligation for derivatives under MiFIR appeared first on EBF.
]]>