MFA has responded to the Commission’s consultation on the MiFID Review. Among its comments are:

  • support for developing exchange-traded products as a complement to OTC products, but notes CESR’s advice that this should be encouraged rather than mandated;
  • automated and high-frequency trading can be beneficial to markets;
  • general support for more disclosure, but concerns about confidentiality;
  • lack of support for any ban on title transfer collateral arrangements for non-retail clients;
  • concern over a “strict equivalence” regime for third countries – which risks being protectionist and restricting EU choice also; and
  • any bans on products, practices or operations must be coordinated even in emergencies.

 (Source: Response to Public Consultation: Review of the Markets in Financial Instruments Directive (MiFID))