The European Securities and Markets Authority (ESMA) recently updated its questions and answers on the following topics:
- On May 29, the revised Markets in Financial Instruments Directive (MiFID II) Q&As on transparency and market structures topics (available here and here, respectively one for transparency and one for market structures). Among other things, ESMA clarifies how it expects post-trade data to be published 15 minutes after publication free of charge and in an easily accessible manner that can be easily copied. Data published by approved publication arrangements and consolidated tape providers must be in a machine readable format; and
- On May 25, Q&As on data reporting under the Markets in Financial Instruments Regulation (MiFIR), (available here). The Q&As clarify the requirements for submission of transaction reports and reference data under MiFIR, particularly in relation to complex trades and national client identifiers for natural persons.
On May 28, ESMA also published guidelines on MiFID II suitability requirements (available here). Investment firms providing investment advice or portfolio management must, under MiFID II and its delegated regulation, provide suitable personal recommendations to their clients or make suitable investment decisions on behalf of their clients.