In its submission, ICMA:
 
• encourages the Commission to consider the full implications of its proposals;
• proposes to expand the definition of ‘admission to trading’;
• recommends that the Commission excludes money market instruments from MiFID;
• asks the Commission to accommodate bilateral trading and hybrid systems within the ‘organised trading facility’ (OTF) category;
• calls for the scope of the non-equity pre-trade transparency framework to be limited to large investment grade bond issues;
• supports CESR’s recommendation not to introduce mandatory pre trade transparency outside the equity market;
• advocates that the post trade transparency framework be based on high/low/median prices published at the end of day, with appropriate delays to accommodate the unique nature of the bond market and phased implementation of the new requirements;
• agrees that title transfer collateral for retail clients should be properly managed, but not prohibited; and
• offers to assist in the development of any further proposals in respect of the underwriting and placing process in the primary market. 

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