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.