The Dutch Authority for the Financial Markets (AFM) sees no technical barriers for the implementation of a consolidated tape (CT) for fixed income. In anticipation of the review of the Markets in Financial Instruments Regulation (MiFIR) by the European Commission (EC), expected on 23 November, the AFM has provided market participants access to the AFM’s Innovation Hub to stimulate the development of a CT.
Based on initial findings, it found no technical barriers or adverse development costs have been identified. The AFM has said it encourages further participation of data infrastructure providers and trading venues in the Innovation Hub.
Since the summer, market participants have been invited to the AFM Innovation Hub to develop CT proof of concepts (PoC). These PoCs enable the AFM and other policy makers to gain insight and experience regarding the most effective solutions and use cases for a CT within Europe's CMU. The initial findings of the project are positive and are expected to contribute to the eventual implementation of a CT that works for all market participants.
At present, the project consists of five fintech participants focussing mostly on fixed income instruments. Despite having distinctive business models, the participants share the common feature that they are existing or starting providers of advanced financial market data analytics.
Using cloud-based infrastructure and solutions, these fintechs could potentially act as consolidated tape providers or digest financial market data for a technology-led CT using advanced programming and analytics capabilities. In most cases, these providers could offer CT data at low costs by leveraging their existing data management analytics capabilities and business models, with additional underlying business cases for value added data services. No technical barriers or adverse development costs have yet been identified which would otherwise prevent the provision of data containing the necessary CT information from trading venues and Approved Publication Arrangements (APAs) towards consolidators.
The AFM says it strongly advocates the implementation of a consolidated tape for equity and bonds on the basis that, “Transparency is key in ensuring that markets are fair, sound and efficient”.
It says a consolidated tape will result in less fragmented price information, as well as other relevant information, in the European markets and will also help in creating a real European Capital Markets Union, improve the level playing field and will improve opportunities for monitoring execution quality (best execution) for market participants and investors.
The AFM has identified several preconditions for a fixed income CT to succeed. First, a Level 1 mandate under the revised MiFIR is needed for trading venues and APAs to contribute the required data fields, tools for managing and supervising the contributions and supporting commercial models.
Second, there is a need to define common data standards, to set required data fields, and to agree on data access and governance models to ensure the efficient working of the CT model.
Third, significant regulatory changes are needed to simplify the current fixed income post-trade deferral regime which hampers the availability of sufficient transaction data.
In addition, as part of its ongoing policy work and discussions with market participants, the AFM has identified four overarching use cases that underline how a CT can provide wide-ranging benefits to a wide variety of markets participants. These use cases clearly demonstrate a CT is an essential element of the Capital Markets Union.
The four use cases it identified are:
Level the playing field and foster the CMU
According to the AFM, the CT democratises access to prices and trade information for issuers and investors by reducing dependency on multiple costly and fragmented data sources:
Enabling EU-wide reference pricing
Availability of accurate reference price information assists greatly with making the right trading and investment decisions. This particularly holds for:
Improving the quality and resilience of public markets
Availability of accurate reference price information leads to increased market transparency, helps to enhance resilience, and provides insights at points of execution for:
Increasing the means for performance and risk management
Availability of price and trade information provides an independent means for improving risk and performance management on EU-wide trading activity, liquidity and pricing.
©Markets Media Europe, 2021
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