• Anne Plested, Business Solutions Consultant at Fidessa


• 28.05.2015 01:00 am
MiFID II , trading , Anne heads up the regulation change programme for Fidessa in Europe. Since joining the firm in 2009 she has played a significant role in the establishment of the Fidessa Regulation Team, monitoring and evaluating the regulatory environment and working on the impact analysis of MiFID II and other major EU regulatory changes running in parallel. Anne is a frequent contributor to a number of industry groups discussing MiFID II, regulation, best practice and post-trade data standards. She is a Member of the Steering Committee for the FIX Trading Community's MMT (Market Model Typology) initiative as well as being a member of, and regular contributor to, their EMEA Regulatory Sub-Committee. In May 2014 Anne was appointed by ESMA as an external stakeholder representative on the Consultative Working Group that supports their Market Data Reporting Working Group. With more than 20 years' experience of the financial markets in London, Anne has previously worked as front-office projects manager, specialising in trading systems, for the retail and institutional divisions of a large private client investment management firm. She has also been involved in numerous projects for a major investment bank and a number of other City firms.

Under MiFID II pre- and post-trade data is required to be made available in an unbundled fashion – ultimately the regulator is aiming to drive down data costs. So where trading venues sell their pre- and post-trade data in the same ‘package’ they will be required to also make it available separately at a reasonable cost. Setting aside the cost discussion, the whole topic of data disaggregation has perhaps slipped under the radar.

In the draft regulatory technical standards (RTS 22) ESMA goes several steps beyond pre- and post-trade data unbundling, including separation by asset class, by instrument, by sector and other criteria subject to customer demand. Asset class alone could dramatically increase the number of products to be offered by exchanges. Splitting out all these data packages, and the resultant administrative overhead, will likely increase costs rather than reduce them. In the absence of common policies and contracts for financial market data across the MiFID region, the management of contractual changes, permissioning, reporting and billing will become even more complex and resource-intensive. The effort required to deliver this degree of change by January 2017 is a concern for those publishing and passing on market data and could also impact those consuming the data. Any change needs to be pragmatic with practical considerations taken into account.

Whilst it’s always good to advocate choice for the customer, the regulators could actually end up making things more confusing and even more expensive.