EFAMA’s response to the Commission’s consultation on the MiFID Review highlights:

  • its concern that the consultation period is too short, and that drafting of new legislation will be rushed;
  • its belief there is no need to change the current definition of “admission to trading”;
  • broad support for general requirements across a range of trading facilities but concern with some of the Commission’s specific proposals;
  • concern at the pace of regulatory action on clearing of derivatives;
  • concerns over the proposals for organised trading, when standardisation is more important;
  • general opposition to many of the proposals relating to tick sizes and high-frequency trading;
  • support for the current regime on order stubs;
  • agreement that the MiFID transparency regime should be extended but only to true exchange traded funds and not to all other UCITS;
  • disagreement with the proposal to make all investment firm quotes public;
  • concern over retrospective bans of products or services; and
  • in relation to product distribution for retail markets, a reiteration of its concern that using different legislative instruments to carry out the PRIPs review may lead to lack of harmonisation.

(Source: EFAMA replies to the European Commission Public Consultation on the Review of the Markets in Financial Instruments Directive (MiFID))