Bats is involved in various industry initiatives around collective understanding of MiFID II. We are active contributors to the following organisations:
- ESMA Secondary Markets Standing Committee Consultative Working Group.
- ESMA Securities and Markets Stakeholders Group.
- FPL MiFID II Sub-Groups:
- Order Data and Record Keeping: Bats' Head of Compliance co-chairs this group, which works with the industry to standardise the manner in which investment firms supply required data to venues. Our approach to record-keeping requirements reflects the work of this group and its goal of a low-impact, but secure, approach.
- Transparency: Bats collaborates with this group to develop collective understanding about pre- and post-trade transparency requirements for equity and non-equity symbols. Input from the FPL MMT committees feeds into this work group and helps to inform our work on Transparency.
- Microstructure: Bats helped develop a pragmatic approach to algorithmic testing. Bats expects to make a range of enhancements to customer UAT environments to facilitate testing in Q2 2016.
- Reference Data: Bats contributes to the collective understanding of reference data implications for APAs, working to identify mechanisms to address the Non-Equity Liquidity Buckets through FIX messaging.
- Best Execution: Bats provides a trading venue perspective in conversations around best execution requirements.
- Clock Synchronisation: Bats collaborates in development of the industry approach to granular timestamping of events. The group's proposal to the FPL Global Technical Committee reflects, in part, Bats' current approach to microsecond level granularity, which has influenced our MiFID II implementation.
FPL MMT Steering and Technical Committees:
- Bats worked with contributors to find a suitable approach to meeting MiFID II Transparency requirements, particularly around trade flagging. As a result, the committee has proposed MMT Version 3.0. Upon adoption of the proposal and mapping to input FIX tags, Bats will incorporate MMTv3 into market data feeds and trade reporting products.
- AFME Fixed Income Venue and Vendors Panel:
- Bats presented its approach to capturing the additional information required to comply with the order record keeping obligations set out in RTS 24. This panel hopes to agree a standardised approach by venues across asset classes.