Etrading Software welcomes the opportunity to comment on ESMA’s Consultation Paper on Guidelines on the MiFID II/ MiFIR obligations on market data.
Etrading Software is the independent, global provider of technology-led solutions designed to assist capital markets institutions and industry initiatives to address complex and constantly evolving market and regulatory challenges. Etrading Software designs, builds and operates technology solutions for the capital markets, allowing clients to keep full governance and control using transparent and vendor-neutral solutions. Working with consortia through a mutualised approach, Etrading Software provides firms with the flexibility to not only meet new market and regulatory requirements but also continue to maintain and enhance such mutualised solutions while allowing stakeholders to retain control of the associated intellectual property and governance. Etrading Software has a European and Asian presence, with headquarters in London, United Kingdom.
In our response to this Consultation Paper, we have focused on technical and operational considerations without regard to the benefits or otherwise of the policy position. Wherever possible our reasoning has relied on objective data based on research we conducted in the summer of 2020. Please see https://www.etradingsoftware.com/wp-content/uploads/2020/10/MiFID-II-Post-Trade-Data-Practical-Considerations-26-October-2020.pdf for further details.
Please click image below to read ETS response in full: