About this initiative
COMMISSION DELEGATED REGULATION (EU) …/... amending Delegated Regulation (EU) 2017/565 as regards the specification of the definition of systematic internalisers for the purposes of that Directive
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Managed Funds Association (United States)
Managed Funds Association (MFA) attaches a comment letter in response to the European Commission's draft Delegated Regulation amending the MiFID 2 Delegated Regulation (EU) 2017/565 on the specification of the definition of systematic internalisers for the purposes of the Directive.
We appreciate the Commission’s proposal and the opportunity to outline concerns relating to the implementation of the MiFID 2 SI regime. We believe the SI regime will not shift current OTC volume in shares onto lit venues as intended and may in fact promote a rise of off-exchange trading in liquid equities. / We welcome the efforts of the Commission to try to tackle this issue – including by doing it in a legally binding way through a change...
Tower Research Capital Europe Limited (United Kingdom)
Tower Research Capital Europe Limited (“Tower”) is a proprietary trading firm and a member of multiple European Regulated Markets and MTFs. Tower deploys its own capital to both make and take liquidity, in a range of asset classes, and participates in multiple trading venue market maker, liquidity provider and specialist programs. Tower is a strong supporter of innovation and competition in the financial services sector and intends to register...
French Banking Federation (France)
The French Banking Federation (FBF) represents the interests of the banking industry in France. Its membership is composed of all credit institutions authorized as banks and doing business in France, i.e. more than 390 commercial, cooperative and mutual banks. FBF member banks have more than 38,000 permanent branches in France. They employ 370,000 people in France and around the world, and serve 48 million customers. The French Banking...
Anonymous (United Kingdom)
We are delighted to have this opportunity to comment on the Commission Delegated Regulation amending Delegated Regulation (EU) 2017/565. We welcome the amendment to the specification of the definition of systematic internalisers, the prioritisation of regulatory intervention from the European Commission on the issue and the recent ESMA Q&A which we believe go a long way towards clarifying the rules in relation to sourcing external...
Federation of European Securities Exchanges (Belgium)
FESE supports the spirit of MiFID II to promote transparency, move trading from OTC markets to regulated trading venues, and firmly differentiate between bilateral and multilateral trading activity to safeguard the price formation process on transparent regulated venues and deliver a level playing field. The objectives of MiFiD II are severely threatened by three major loopholes giving an unfair and unjustified advantage to trading on SIs....