infrastructure investment will be key for both Barclays Equities and our clients alike ,” he says .
“ Technology is enabling much greater transparency , detailed monitoring and governance and offers the possibility for standardisation going forward .” UBS ’ s Semark adds : ’“ With MiFID II there is a lot of time and effort going into producing data and I would argue this is a drain on resources with no huge benefit for end clients .”
The original MiFID II proposals required firms to publish data for each of its top five execution venues , based upon trading volumes for orders executed for both retail clients and professional clients .
The regulations state that such information has to be published in separate tables and in a combined table , as information may need to be published for up to 10 execution venues .
Some respondents argued that as they execute client orders with a very large number of brokers it is disproportionate to require them to list every single
RTO ( reject taking order ) / placing policy of the execution venue or entity used .
Other respondents suggested that there needed more clarity on when investment firms are
executing transactions and when they are transmitting and placing orders with other entities for execution .
SEEING SENSE Thankfully , ESMA is listening . It has subsequently clarified the advice to require investment firms to provide the list of execution venues and entities used for each class of financial instrument .
It has also amended the advice to clarify that the information to
THE COMBINATION OF UNBUNDLING AND A FOCUS ON BEST EXECUTION IS A POSITIVE FOR PERFORMANCE AND THEREFORE FOR END CLIENTS .
RICHARD SEMARK , HEAD OF EUROPEAN CLIENT EXECUTION STRATEGY & HEAD OF UBS MTF
execution venue or entity they use for each category of financial instrument .
Others raised issues with the difficulty of updating this list while some argued that it should be sufficient to summarise on the investment firm ’ s website information on the execution or be provided to clients on the execution or RTO / placing policy should state that entities other than trading venues can be used for execution and the consequences of counterparty risk .
Regardless of these clarifications and updates , data needs to be published for a wide-ranging set of financial instruments , including equities , debt instruments , interest rates , credit , currency , equity , securitised and commodities derivatives ( listed futures and options and swaps , forwards and
GIVEN THE HUGE AMOUNTS OF DATA AND SPEED REQUIRED , INFRASTRUCTURE INVESTMENT WILL BE KEY FOR BOTH BARCLAYS EQUITIES AND OUR CLIENTS ALIKE .
NEAL HALLETT , HEAD OF EMEA CASH TRADING AT BARCLAYS other derivatives ), CFDs and emission allowances .
Ultimately , the industry is working hard to implement MiFID II and recognises the benefits that the spotlight on best execution will provide .
Semark says that at UBS they continually monitor and optimise their platform to ensure it is effective and aligned with what the client is trying to achieve : “ That is something that we work on constantly and the framework is aligned with the FCA ’ s thematic review ; that work is all positive and beneficial , especially regarding transparency for clients ,” he says .
“ Having a greater focus on best execution is a very positive development because having that as the sole determinant of where fund managers are directing their order flow is clearly going to give a better outcome to clients than we have seen before ,” he says .
“ So the combination of unbundling and a focus on best execution is a positive for performance and therefore for end clients .” l
10 | THE TRADE MiFID II HANDBOOK www . thetradenews . com