APCIMS has responded to the Commission’s call for evidence on MAD. It generally supports most of the Commission’s ideas, including:  

  • to extend MAD’s scope to MTFs;  
  • to align the MAD definition of “financial instrument” with MiFID’s;  
  • that there is no need to change the definition of market manipulation; and  
  • while a framework dealing with short selling might be more useful than the current national fragmented approaches, MAD is not the place to deal with it.