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May 29, 2018

ESMA updated question and answer (Q&A) document on data reporting under the Markets in Financial Instruments Regulation (MiFIR). Additional Q&A updates involve investor protection topics, in addition to the transparency and market structures issues under Market in Financial Instruments Directive (MiFID II) and MiFIR.

The updated Q&A include the following:

  • Q&A on data reporting under MiFIR—The Q&As provide clarifications in relation to the requirements for submission of transaction reports and reference data under MiFIR. In particular, the Q&As relate to Complex Trades and National client identifiers for natural persons. The Q&As on complex trades provide new answers on reporting transactions and reference data for instruments where the execution results in a complex trade. The Q&A on national client identifiers for natural persons further clarifies how the three national identifiers—the Czech ID, the Liechtensteinian ID, and the Romanian ID—should be represented.
  • Q&A on investor protection topics under MiFID/MiFIR—The updated Q&A document covers the topics of best execution, client categorization, provision of investment services and activities by third country firms, suitability and appropriateness, post-sale reporting, and underwriting and placement of a financial instrument.
  • Q&A on transparency and market structures issues under MiFID/MiFIR—The updated Q&As provide clarification on the requirements to publish information on post-trade data 15 minutes after publication free of charge; the publication of transactions and how to populate the field publication date and time; pre-trade transparency requirements for voice trading systems and for request for quote systems; and Organized Trading Facilities (OTFs) arranging trading in strategies that include an equity leg.

The Q&A mechanism is a practical convergence tool used to promote common supervisory approaches and practices. It is intended to help investors and other market participants by providing clarity on the requirements.


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Keywords: Europe, EU, Securities, MiFID/MiFIR, Q&A, Data Reporting, Investor Protection, Market Structure Issues, ESMA

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