EFAMA comments on MiFID Transaction Reporting Requirements

10 January 2007

EFAMA issued its comments on CESR’s MiFID Transaction Reporting Requirements noting that reporting should be limited to what is necessary to identify transactions that need to be investigated. EFAMA does not believe that asset managers in most cases fall under the obligations of Art. 25(3), as they do not “execute transactions” when they utilize an intermediary such as a broker. As MiFID does not explicitly foresee multiple reports being made, EFAMA believes that a single report is sufficient to fulfil the goal of upholding the integrity of markets.

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