The Investment Management Association has responded to the European Commissions' Consultation on its review of MiFID. The IMA has said that whilst it understands why the Commission is keen to draw up a comprehensive framework within which trading in all financial markets may operate, it cautions that detailed rules which fail to take account of the specifics of different instruments and trading conventions will not achieve this goal. It said that rules for non-equity markets should be specific to each instrument and should not necessarily be modelled on equity markets. It also said that transparency rules cannot be made for non-equity markets in general. Each market must be considered separately.
The Federation of European Securities Exchange and the EVCA have also published their responses. They express concern that the application of MiFID to private equity and venture capital is not the same across member states. While in some securities of private companies will be considered to fall within the scope, this may not be the case elsewhere. They seek clarification concerning the scope of MiFID and, in particular, its application to securities of private companies in the context of private equity and venture capital activity.