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It also highlights a number of issues not originally in the Draft Recommendation but which also need to be addressed, such as improvements to best execution in line with the First Reading of the Parliament.
On the Systematic Internalisation Definition of the Common Position proposes a definition of “systematic internaliser” which contrasts with the definition of “systematic internalisation” in the Parliament’s first reading. This would create a sub-category of investment firms which are to be defined as “systematic internalisers”. This contradicts the two-year long consultation in the pre-legislative stage which supported retaining the existing division between investment firms and regulated markets.
On pre-trade transparency obligations FBE also supports the results of the Parliaments first reading, and the amendments recommended for the second reading. In particular, FBE supports the view that Quote size should be “standard market size”, Banks should be protected against the risks of multiple hits against the quoted prices, and the comitology provisions should provide clear guidance to the Commission.