FESE response to the UK FCA consultation on improving transparency for bond and derivative markets

Generally, FESE believes that the pre-trade transparency regime needs to be simplified and made more coherent for the market.

• FESE considers that the number of options available in the post-transparency regime should be reduced, in particular waivers that enable only partial publication or no publication of trades as well as the 4-week waiver. We do not favour long deferral periods.
• For the reasons to increase transparency, FESE does not agree with the FCA proposal to completely remove pre-trade transparency for investment firms (including SIs). On the contrary, pre-trade transparency requirements for SIs should be better enforced and simplified to increase data quality.
• FESE suggests reducing the complexity of the current framework by only allowing one timeframe for deferred publication, irrespective of which waiver is used.