Response to ESMA Consultation on MiFIR Reporting Review

On November 20, 2020, MFA sent a letter to the European Securities and Markets Authority (ESMA) in response to its consultation on “MiFIR Review Report on Obligations to Report Transactions and Reference Data.”

MFA supports ESMA’s efforts to extend reporting requirements to derivative transactions traded “off venue,” as this would increase transparency for members and the market in general. We also support ESMA’s proposal to streamline the reporting of algorithmic identifiers and short sale positions through the use of indicators, including the removal of the indicator altogether. MFA however disagrees with ESMA’s proposal to include AIFMs and UCITS in additional MiFID II reporting requirements. This would impose a costly burden on members and is likely to produce no further insight into transactions at their firms.