Response to the ESMA consultation paper on the functioning of the OTF regime

We welcome ESMA’s decision to tackle some of the issues at the core of the market structure debate in this consultation. In particular, we support ESMA’s reflections on the need to amend the Level 1 text to further clarify the definition of an SI. We would suggest broadening the scope of such reflections to include the perspective of equity markets. We strongly believe that a simplified market structure would strengthen lit markets, support active price formation and the generation of robust reference prices.   We support ESMA in addressing the disparity when it comes to the authorisation of multilateral systems and investigating further the concept of multilateral trading and networks of SIs.