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[ A D V E R T O R I A L ] MIFID II TRADE TRANSPARENCY EXPLAINED The TRADE speaks with commercial director at TRADEcho, Per Loven, about how trade transparency requirements under MiFID II differ from MiFID and according to asset class, and how firms can use technology to help ease the reporting compliance burden. Per Loven, commercial director, TRADEcho The TRADE: Trade transparency requirements are changing dramatically under MiFID II. How will this affect market participants? Per Loven: There are fundamental changes in terms of trade transparency between MiFID as it stands today and MiFID II. MiFID - which came into effect in 2007 - required firms that executed trades OTC to report them for equities and equity-related instru- ments. This was the first step towards trade transparency in the OTC space, and we have been servicing the market as a trade data monitor (TDM) ever since. Today, our part- nership with the London Stock Exchange has seen the creation of TRADEcho, which is the approved publication arrangement (APA) for trade transparency under MiFID II. TRADEcho will cover all asset classes, every instrument in terms of pre- and post-trade transparency in Europe. “These changes will affect fixed income market participants in a profound way.” For MiFID II, the requirements change from covering only equities and equity relat- ed instruments, to a much broader universe, including fixed income and derivatives. The instrument universe affected will go 42 TheTrade Spring 2017 from some 7,000 instruments to somewhere between 15 and 20 million instruments. It’s hard to say at this point because we don’t know exactly in terms of packaged deals and derivatives contracts. It also involves enhanced transparency on the pre-trade side under the systematic internaliser regime. Banks and brokers who today run broker crossing networks (BCNs) will under MiFID II, to a large extent, operate as systematic internalisers, which involves pre-quoting requirements. Furthermore, the hierarchy around who has the reporting obligation in any given scenario is defined to a detailed extent under MiFID II. This is very different from today, where no clear rules around this exist, something leading to continuous over reporting, distorting the view of real liquidity in the market. Under MiFID II, if a trade is executed on a venue (Regulated Market or MTF), then the venue will report the trade to the market. If the trade is executed against a systematic internaliser, then the systematic internaliser has the reporting obligation. In other scenarios, it’s the seller’s obligation to report the trade. Ultimately, the main changes can be out- lined as: • E  xtension of instruments covered, from