FESE response to the ESMA consultation on CTP and DRSPs

FESE wishes to thank ESMA for its work on the challenging task of developing draft technical standards related to CTPs. FESE welcomes many of the proposals and has leveraged the expertise of its members as future data contributors to provide thoughtful feedback on certain elements that could be refined. These include but are not limited to:

• The proposed minimum latency requirements for data submission should be finetuned, as these may not always be technically feasible for all participants.
• We discourage the use of JSON for data transmission. Instead, we suggest leveraging existing formats and protocols, and if a new protocol is defined, it should be uniform across all asset classes.
• The input data for the CTP should be limited to what is necessary for the CTP to be operational; therefore, we have concerns about an automatic link with RTS 2 for the bonds tape.
• The CTP should not be expected to enhance the quality of the data provided in terms of specific content; this responsibility should rest with the data contributors, who have systems and controls in place to ensure data quality.
• A dedicated RCB framework is needed for the CTP, which takes into account the underlying costs incurred by data providers for the production and transmission of data.
• The potential provision of value-added services by the CTP would present issues from a competition standpoint vis-à-vis data providers and data vendors.