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We
believe that an appropriately constructed consolidated tape (“CT”)
could help to build deeper and more open capital markets in Europe. In
line with the European Commission’s vision for the Capital Markets
Union, a key aim should be to democratise access across European markets
to provide all investors regardless of resources or sophistication with
a comprehensive and standardised view of European trading.
Our
members do not believe that a CT is the solution to the concerning
issue of increasing market data costs. This issue must be addressed
head-on, including through the proper enforcement of the MiFID II and
MiFIR requirements, standardisation of pricelists, policies, audit
procedures, etc.**, regardless of the existence of a CT.
The
two issues are nevertheless connected as the commercial viability of
the consolidated tape provider (CTP) will be closely connected to the
price at which it obtains input data from trading venues and Approved
Publication Arrangements (APAs) as well.
We
look forward to engaging with the Commission and regulators over the
coming months to address the challenges relating to the development of a
CT and the issue of increasing market data costs.