Amendments to the Markets in Financial Instruments Directive (MiFID 2)

The Alternative Investment Management Association (AIMA) welcomes the opportunity to provide its views on the European Commission’s (the ‘Commission’) Proposal for a Regulation of the European Parliament (the ‘Parliament’) and of the Council of the EU (the ‘Council’) amending Regulation No 600/2014 (MiFIR) and Proposal for a Directive of the Parliament and of the Council amending Directive 2014/65/EU (MiFID II)…

FESE very much welcomes the removal of the open-access provisions for exchange-traded derivatives, the prohibition of payment for order flow, and the removal of the exception to the exemption from authorization as investment firm for DEA users, which together will make markets stronger. However, some points deserve further reflection: 1.

04 March 2022. The members of the European Venues & Intermediaries Association were pleased that the Commission was able to release its MiFID II Review proposals at the end of last year. Having taken the opportunity to review and consider them, EVIA is supportive of several elements which will advance the CMU project and more effectively implement the MiFID II package.

I. Deletion of Art. 27 (3) MiFID II The German Banking Industry Committee (GBIC) welcomes the European Commission (EC) legislative proposal dated 25th November 2021 to delete Article 27 (3) MiFID II (RTS 27 reporting). GBIC shares the view of the EC that the RTS 27 reporting provides almost no added value to investors and the public. The decision to abolish the requirements of Art.

Deutsche Börse Group (DBG) appreciates the opportunity to give feedback on the roadmap regarding the review of the MiFID II/MiFIR framework. We share the European Commission’s view that the targeted MIFID II/MiFIR review is urgently needed to improve the functioning and transparency of EU financial markets.

Please find below ESBG comments to the roadmap: 1. Investor protection ESBG supports the Commission’s analysis that several requirements in MiFID, which were aimed to increase investor protection, prove to be extremely costly and bring little added value for investors.

1. Investor protection GBIC supports the Commission’s analysis that several requirements in MiFID, which aimed to increase investor protection, prove to be extremely costly and bring little added value for investors. Banks and saving banks experienced that many clients did not welcome the changes introduced by MiFID II and complained about the amount of often unhelpful information and mandatory voice recording.

The European Federation of Energy Traders (EFET) welcomes the opportunity to provide feedback on the roadmap to the review of the regulatory framework for investment firms and market operators (Review of the MiFID II/MiFIR framework).

We especially welcome the European Commission’s readiness and efforts to review, in the common interest, the myriad of rules and provision in this field. A joint dialogue of all stakeholders involved (authorities, consumers, industry) can lead to optimal results, especially for consumers. We appreciate the Commission’s evaluation that the MIFID II/MiFIR framework needs an appropriate rebalancing of the provisions.