Position papers

Response to ESMA Consultation on Package Transactions

Created: Tuesday, 03 January 2017 11:55

In its response, FESE argues that the proposal by ESMA would result in a more restrictive pre-trade transparency regime for package orders than for individual transactions. The proposed approach would result in the vast majority of exchange traded derivatives packages being determined as liquid, meaning the waiver could not be applied to them. Furthermore, the proposed methodology concentrates on characteristics of individual components of the package rather than assessing the package as a whole.

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Response to ESMA Consultation Paper on Guidelines on the calibration, publication and reporting of trading halts

Created: Tuesday, 06 December 2016 15:20

FESE believes that safeguard mechanisms are fundamental in preventing or limiting the occurrence of extraordinary volatility events or the so-called “flash crashes” in equity markets. Over the past years, and in many cases prior to MiFID I implementation, many European trading venues have successfully implemented safeguard mechanisms.

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Response to ESMA CP on RTS specifying the scope of the consolidated tape for non-equity financial instruments

Created: Tuesday, 06 December 2016 15:17

In line with our views on equity data consolidation, FESE believe that any initiative must aim to achieve a meaningful market data consolidation in a multi‐venue world.

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Response to ESMA on the Benchmarks Regulation Consultation Paper

Created: Monday, 05 December 2016 11:19

FESE supports working with ESMA to construct a workable regime for benchmarks provided by trading venues. FESE’s response to the ESMA consultation on technical standards for the Benchmark Regulation focuses on the main following areas: the definition of regulated data, transitional provisions, third country provisions, exemptions to the benchmark methodology in case of sudden market events and the provisions for code of conducts and compliance statements.

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Response to ESMA Discussion Paper on Trading Obligation for Derivatives

Created: Tuesday, 22 November 2016 13:32

In its response, FESE urges ESMA to consider the overall impact the work on the EMIR Clearing Obligation will ultimately have on the final implementation of the MiFIR Trading Obligation, since any instrument which does not fall under the scope of the EMIR Clearing Obligation will not be eligible for the MiFIR Trading Obligation.

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