Our Secondary Markets Expert Group contributed to our response to ESMA's Consultation on MiFID II/MiFIR (ESMA/2014/1570).
We noted that the concerns of respondents about the inclusion of systematic internalisers, market makers and other liquidity providers within the definition of execution venues have not been addressed, and urged ESMA to follow the Commission’s recommendations and not impose restrictions to equity market makers.
We supported a deferral period of up to two days delayed publication for less liquid securities in ESMA’s new ADT class (ADT < €50,000), subject to the publication of the detail of this class.
We welcomed ESMA’s clarification regarding the new obligations in MIFID II for investment firms engaged in algorithmic trading that pursues a market making strategy. However, we noted that ESMA should ensure that the classification and rules applicable to other existing market making models recognised under MiFID I remain unchanged.
Finally, we supported that the tick sizes that are applied to small and mid-size quoted companies’ stocks are better assessed and take into consideration specific market circumstances.
Click here to download the response (pdf)