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With regard to investor protection and transparency issues, the FBE does not see the value added of applying a pre- and post-trade transparency regime designed for the equities markets to the characteristically and structurally distinct non-equity markets, especially if investor protection is the stated rationale for doing so.
With regard to timing considerations, the FBE reminds that it already called on the Commission to consider postponing any judgement and subsequent policy decisions in respect of transparency in the non-equity markets until the financial industry and regulatory authorities could make a fair assessment of the effectiveness of systems and the opportunities MiFID is designed to deliver.