Bats' plans with regards to APA services for MiFID II.
Subject to regulatory approval, Bats will take its existing FCA Trade Data Monitor (“TDM”) status forward into the APA regime under MiFID II and plans to operate an APA under our Recognised Investment Exchange status.
The Key Features of the proposed APA service include:
- Support for the equity and equity like universe of securities as specified in RTS1.
- Support for OTC reports in Swiss equity instruments by virtue of holding Trade Data Monitor Status with SIX Swiss Exchange.
- Support for deferred trade reporting as per the updated MIFID ADT rules.
- A suite of web-based administrative tools.
- An open connectivity model permitting other vendors and APAs to pass trade flows into the Bats APA.
- Trade submission is performed either via standard FIX interfaces or via the “Assisted Reporting Model” outlined below.
Benefits of the proposed APA service include:
- Domain expertise by virtue of running a MiFID I pre-cursor to APA services.
- Firms who are Participants of Bats Europe can utilise their existing physical infrastructure.
- Wide distribution of trade data to data vendors and trading firms.
- Benefit from many large firms’ intention to utilise Bats’ APA services.
Direct and Assisted Reporting models.
The Direct Reporting model is the standard model where firms can themselves submit trades electronically via a FIX or BOE interface. For technical information relating to the interfaces please see our MiFID document library.
The Assisted Reporting model permits Investment Firms (typically buy-side) to utilise the technology of counterparties to assist them in meeting their regulatory responsibilities.
Under this model, firms would require a standard contractual relationship with Bats and be subject to the standard pricing.
- Buy side – Provides a low-cost, lightweight solution for trade reporting obligations
- Buy side – reduced integration and ongoing costs (connectivity, ports)
- Buy side – APA delivery risk reduced
- Buy side – access to full range of tools as if they were directly connected
- Sell side – changes to reporting logic would be more limited than if many buy side decided to report themselves when required
- Both buy and sell side – limits scope for proliferation of equity APAs, commercial and technical costs associated with re-aggregation of data from many sources
The diagram below illustrates the Assisted Reporting model.