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The Investment Management Association (IMA) has worked for comprehensive and understandable disclosure of costs and charges throughout the investment manufacturing and distribution chain. The IMA supports ESMA's proposals to deliver this objective while leaving space for national regulators to determine the precise form. We look forward to working further with domestic and European regulators to ensure that consumers have access to meaningful information.
The current European trading rules generally serve investors well. The IMA supports regulators' efforts to introduce more transparency with respect to buying and selling interests in capital markets. We will now work to ensure that the proposed rules do not hamper market liquidity or our ability to achieve best execution for European investors. A regulatory framework that ensures free and fair competition between European trading venues and dismantles national champions will best serve end investors.
The IMA agrees with the European Commission that market data costs in Europe are too high and need to come down. ESMA's preference for a transparency-only approach to pricing will not achieve the European Commission's mandate. The IMA continues to believe that only a combination of transparency and the use of Long Run Incremental Cost Plus (the same method applied to mobile roaming data charges as a way for an exchange to cover costs, plus an 'appropriate' mark-up) – will lower market data charges in Europe.