FESE welcomes the IOSCO consultation report on market data in the secondary equity markets. We agree with IOSCO that it is paramount to enable market participants to make informed decisions regarding investments, order routing, and trading. At the same time, the non-discriminatory basis provisions should not overlook that different types of market participants have different market data needs, and that the data elements and latency necessary for one market participant may not necessarily be the same for another. Financial regulation is highly heterogeneous across the globe, often reflecting the maturity and unique characteristics of each market, and as such the respective market data needs may also differ.
In order to evaluate the changes in overall costs of and fees for market data, it is important first to look at the wider market data ecosystem and avoid the confusion between overall data procurement costs and market data fees levied by trading venues. In addition, while trading venues are at the forefront of transparent, secure and stable markets, the same cannot always be said for less transparent markets. Market data is an essential element of price discovery and helps support fair and efficient markets. FESE therefore strongly recommends that IOSCO considers fair competition as an indispensable value that must be protected. The freeriding of entities able to derive unfair competitive advantages should be avoided.
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