MFA submitted a comment letter to the European Securities and Markets Authority’s (“ESMA”) on its MiFIR Review Consultation Package. A summary of the key points is as follows:
- ESMA’s proposal for liquidity assessment based on issuance size thresholds aligns with the FCA’s approach in the UK.
- MFA urges ESMA to calibrate post-trade LiS thresholds and deferral periods to optimize market data access while managing risk for large or less liquid trades.
- MFA supports ESMA’s approach of identifying specific costs related to market data production and dissemination.
- MFA agrees that market data pricing should reflect efficient production and distribution costs with a reasonable mark-up.
- MFA recommends simplifying and standardizing market data licensing practices across trading venues and data providers.
- MFA generally supports ESMA’s proposals on pre-contractual obligations, fair terms, market data agreements, conformity with policies, and fee provisions, with specific revisions outlined in the Annex.
