MiFID/MiFIR and transparency for OTC derivatives
International Swaps and Derivatives Association
February 15, 2012
ISDA has published a paper on the nature of trading structures and liquidity formation in OTC derivatives markets and the associated implications under MIFID2/MIFIR.
The publication makes the following recommendations:
(i) a redraft or replace Article 7 of MiFIR to accommodate trading systems other than order book systems without relying on the waiver process; and (ii) the removal of the quote-sharing obligation from Article 17.