MiFID-R Briefing - Non-equity and importance of aggregated publication

November 07, 2014


It is important to balance the need of transparency and liquidity, in particular for smaller non-equity markets dependent on market makers/SIs. Our view is that restrictions of aggregated publication on level 2, as proposed by ESMA in its Discussion Paper, must be avoided since it would harm the liquidity in small government bond markets and thereby increase the costs for managing the national debt. The proposal also limits SMEs possibility to access and get funding at the capital markets. Thereby the proposals make it difficult to achieve the Commissions’ vision of creating a Capital Markets Union.