FESE strongly supports ESMA’s proposal to clarify that Systematic Internalisers’ quotes would only reflect prevailing market conditions where the price levels could be traded on a trading venue at the time of publication. We welcome ESMA’s initiative to clarify this issue which we consider to be a necessary development in order to deliver on the objectives of MiFID II/MiFIR and therefore urge ESMA and the Commission to move speedily to adopt this amendment to the Level 2 framework.

Whilst the ESMA proposal to amend RTS 1 is a step in the right direction, the market above Standard Market Size (SMS) is still open to the risk of tick size arbitrage by SIs. In light of this, FESE is supportive of calls for an amendment to the Level 1 framework to extend the minimum tick size regime to SIs trading in all sizes. In advance of such Level 1 changes being agreed upon and implemented, FESE believes it would also be worth exploring additional interim solutions within the Level 2 framework which could be applied relatively quickly. Such an approach could involve a small revision to the methodology for the SMS calculation with a view to increasing the level and thus covering larger orders.

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