IMA’s response to the Commission’s consultation on the MiFID Review:

  • supports the Commission’s efforts to address quality of post-trade data in the equity markets;
  • supports the introduction of a category of “Organised Trading Facility” but asks also for this to be divided into subgroups, but does not think transparency rules are suitable for non-equity markets generally;
  • does not agree that UCITS should be split into complex and non-complex products;
  • supports a level playing field for marketing retail investment products and says the permitted “article 4” notification of gold-plating regime should be reviewed in this light;
  • insists that third country access by exemptive relief is crucial; and
  • stresses the importance of effective enforcement.

(Source: Press Release and Review of the Markets in Financial Instruments Directive)