Response to ESMA Consultation on Market Data

On January 11, 2021 MFA and AIMA submitted a joint response to ESMA’s consultation entitled, “Guidelines on the MiFID II/ MiFIR obligations on market data.” Our response highlights the importance of access to market data and notes the increasing cost of market data from trading venues and third-party vendors. In general, the Associations support ESMA’s proposed guidelines on market data, including the proposals to standardize reporting formats, increase transparency in pricing methodologies, and set fees based on user identifications rather than per individual device. We also raised concerns regarding issues surrounding the unbundling and bundling of products which results in firms spending resources on products they do not need and recommended that ESMA instead promote guidelines requiring vendors and venues to better tailor products to suit specific client needs.