Europex response to ESMA’s Opinion on the trading venue perimeter

Europex welcomes the opportunity to provide feedback to ESMA’s Opinion on the Trading Venue Perimeter. In the consultation, we make the following two remarks:

  • We do not agree with the view that a system where on one side of any trade (buy side or sell side) there is always the same party should be considered multilateral simply because the system is operated by a third party (draft ESMA opinion no. 24).
  • We do not agree with the assumption that the pre-arranging system is outsourcing the trade conclusion to the trading venue and hence should be considered responsible for the pre-arranging firm fulfilling all regulatory and legal requirements.

For more detailed information, please read our full response here.