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The Committee of European Securities Regulators (CESR), last Friday, published its first two papers containing guidelines and recommendations on the implementation of the Markets in Financial Instruments Directive (MiFID) – EU Directive 2004/39/CE. These covered the publication and consolidation of Market Data, and the list of minimum Record Keeping requirements.
The first set, that on publication and consolidation of market information recognizes that, under MiFID, there will be no single regulated market for publication of pre- and post-trade information, instead a potential plethora of regulated markets, multilateral trading facilities, systematic internalisers and over-the-counter facilities. The guidelines therefore concentrate on tha accuracy, timeliness and format of data, ensuring that is can easily be consolidated. Publication on one primary publication channel will be seen as compliant with MiFID provisions and the expectation is that private sector information consolidators will appear.
The second set of guidelines, is a straightforward list of minimum records of all services and transactions that a firm will need to maintain under MiFID and gives the type of records and indicates the content and the time at which these records should be created. It does not cover the client policies of firms and it acknowledges that this is a minimum list which may be added to by regulators.
Both papers are accompanied by feedback statements summarising the comments received by CESR in its consultation exercise, plus explanations on CESR’s final approach to significant issues. These are the first pieces of definitive Level 3 work released with the aim of ensuring implementation consistency in the way that the MiFID requirements are interpreted by the Member State regulatory authorities.
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