FIA EPTA welcomes the opportunity to respond to the ESMA consultation on the MiFIR pre-trade transparency regime for systematic internalisers (SI) active in non-equity instruments. FIA EPTA members note that for OTC derivatives, SI pre-trade transparency is limited to instruments that are considered “traded on a trading venue” (ToTV), as SIs have generally opted-in only for ToTV instruments. FIA EPTA members believe changes must be made to the concept of ToTV before SI pre-trade transparency can be considered meaningful. In assessing the overall SI transparency regime, it would be helpful for ESMA to attempt to determine total ToTV trading volumes vs. total off-venue trading volumes per asset class.
- FIA EPTA