AFME has commented on the outcome of the negotiations regarding the MiFIR file. While AFME acknowledges the achievement of reaching a political agreement on this important regulation, they express concerns about certain aspects of the deal that may lead to suboptimal outcomes.
AFME particularly regrets the loss of the opportunity to create a real-time equity consolidated tape with sufficient pre-trade information, which could have reduced market data costs and improved Europe’s competitiveness. They also criticize the detailed rules regulating fixed income markets, arguing that they fail to consider the fast-evolving nature of financial markets and may work to the detriment of EU capital market users and strategic autonomy.
AFME supports some efforts to mitigate trading restrictions but questions the merits of placing a minimum floor on alternative execution venues. They welcome the removal of pre-trade transparency for bonds to align with global practices, but express disappointment at the lack of evidence for changes to post-trade transparency and the inflexible deferral framework. AFME intends to analyze the full agreement and engage with ESMA regarding the level 2 mandates it has received.
