MFA has submitted a comment letter in support of the goals of the European Securities and Markets Authority’s (ESMA) proposal to enhance access to market data through improvements to the MiFID II/MiFIR regime.
The letter is in response to an ESMA consultation on technical standards related to the transparency regime for non-equity instruments and provision of market data on a reasonable commercial basis.
“The ESMA proposal will improve market participants’ access to affordable, accurate, and timely market data. This will help deliver on the promise of the Capital Markets Union by enhancing the transparency, competitiveness, and efficiency of EU capital markets,” said Bryan Corbett, MFA President and CEO.
MFA’s letter supports measures in the ESMA proposal that make the pricing of market data more transparent and subject to regulatory scrutiny. This includes requiring trading venues and approved publication arrangements to break out their market data costs into specific categories, justify their cost allocations, and explain any proposed fee differences between customer types. Increased price transparency will ensure market participants have access to affordable, accurate, and timely market data. The proposal’s measures on price transparency will strengthen EU capital markets by making price discovery more efficient and markets more liquid.
MFA’s letter highlights that volume of data and speed of delivery are appropriate metrics that should factor into pricing, but that pricing should not vary based on a subscriber’s intended use.
In the letter the MFA wrote: “MFA strongly believes that data prices should not vary based on how an individual user intends to use the data or the user’s business model. Charging different customers different prices for the same data is inherently discriminatory. The value of market data to a user is highly subjective and not an appropriate metric for pricing. Market data users should pay the same objective, cost-based price for the same data.”
