Mifid II: banks reveal package trading obligation workarounds

  • Banks, trade associations and lawyers explain the range of bespoke temporary workarounds the market has found to Mifid II’s complex trading obligation rules and how they apply to packaged trades;
  • But more regulatory guidance would be welcome to form an industry-wide approach as it’s not entirely clear what the rules even mean;
  • The current best efforts workaround is arranging and executing trades off-venue then booking onto a venue after the fact to comply with reporting rules – but this is far from an ideal solution;
  • Trades are also being slowed down over disagreements as to what even qualifies as TOTV.

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