Responding to CESR’s call for evidence on ISD, the Federation of European Securities Exchanges (FESE) argues that on the issue of best execution,
FESE does not expect
CESR to come up with a decision on any minimum number of execution venues that an investment firm shall establish access to.
It is conceivable that the deliberate decision by a firm to link up to only one execution venue will save costs and benefit the customer. The explanation of the firm's execution policy will in our view have to include, among other information, a certain rationale in what circumstances and for what types of business the firm screens and uses what venues.
With regard to the Organisational requirements, it is currently not yet decided in the legislative process whether and in which form the provisions of Art. 13 of the Directive will become applicable to Regulated Markets when operating an MTF.
CESR regulators are requested at 'concrete organisational requirements to be imposed on investment firms performing different investment services'. This invites developing a distinct approach to those investment firms that operate an MTF as their sole investment service.
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