FIA EPTA appreciates the opportunity to respond to the FCA’s Consultation Paper 22/18 on Guidance on the trading venue perimeter. FIA EPTA memberswelcome the FCA’s proposed guidance and are generally in agreement with the FCA’s intended approach the FCA, which we consider to be proportionate and providing for an appropriate degree of clarity to market participants regarding whether the FCA would characterise a specific system as multilateral or not. Our substantive comments are relation to the following: The scope of the FCA’s proposed guidance regarding “blocking” (Q6), which we consider should be clarified to be relating specifically to practices in the listed derivatives markets only;
Further, we have identified two areas which are not covered in the currently proposed guidance but where FIA EPTA members observe market practices that seem to be multilateral in nature while not currently being subject to trading venue authorisation. This is in relation to: Retail Service Providers (RSP) systems operated by non-authorised third-party service providers (ISVs); and De-facto riskless or quasi-multilateral SI activity
