ISDA has expressed concerns over two elements of EP’s report on MiFID 2/MiFIR that limit investor choice. By proposing limitations on when derivatives can be executed on an Organised Trading Facility (OTF), EP is pushing transactions towards more exchange-like venues, a model based on equities trading but not suitable for all derivatives. EP’s proposals would also ban OTF operators from using proprietary capital and making markets, thus limiting the ability of OTF operators to offer services to clients. (Source: ISDA Comments on EP MiFID 2 Vote)