FESE comments on Draft Level II Measures for MiFID

02 September 2005

The Federation of European Securities Exchanges (FESE) published its responses on the Commission Working Document on draft level II measures for MiFID. FESE main concerns n relation to the Commission’s draft instrument on market transparency include that some of the definitions or classifications in the instrument may still warrant additional consideration as they could jeopardise existing or hinder future developments on Europe’s Exchanges. FESE objects to the national choice between the two quantitative criteria for “liquid shares” as such an option is in our view unnecessary and would stand in the way of even MiFID implementation across the EU.

FESE also sees no justification whatsoever to suddenly introduce the cross-reference from pre-trade transparency exemptions to post-trade deferrals. The Federation is concerned about the “invitation” to Member States by the Commission to indicate whether more detailed requirements for shares to be admitted to a Regulated Market should be laid down. We strongly recommend against any stricter ex-ante requirements.

Document

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