ESMA consultation on RTS 1 & 2 under MiFIR: EBF High level comments

CONSULTATION RESPONSE
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ESMA consultation on RTS 1 & 2 under MiFIR: EBF High level comments
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BRUSSELS, 30 September 2021 - The EBF would like to thank ESMA for the opportunity to comment on the proposed changes on RTS 1 & 2 under MIFIR.

The EBF would like to share some concerns regarding this consultation on the following:

• Timing: it is highly important to ensure that all amendments are made subject to a thorough cost/benefit analysis and to avoid temporary solutions that may be overhauled by a forthcoming MiFID Review


• Mandate: EBF has some concerns regarding ESMA’s mandate to propose certain changes


• Alignment between MAR and transparency requirements under MIFIR : it is key to clarify that it would be allowed for an investment firm not to publish a transaction under the transparency rules if such publication would be in contravention with MAR


• Streamlining: While we generally support the intention to reduce overlaps and to streamline above mentioned articles, we are not entirely convinced that the some reference are sufficiently unambiguous.

 
More information:
Pauline Guérin, Senior Policy Adviser, Financing Growth p.guerin@ebf.eu
 

EMSA consultation on RTS 1 & 2 under MiFIR: EBF High level comments