MiFID II and MiFIR, was implemented on January 3rd 2018 and required major implementation efforts. Tradeweb continues to help clients adhere to MiFID II requirements; our solutions encompass all pre-trade, execution and post-trade obligations.
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The implementation of post-trade transparency rules will require transaction details to be reported either real-time or with a deferral across a wide range of asset classes. Transactions executed on trading venues will be reported by that venue, while transactions executed off-venue will need to be reported by one of the counterparties to the trade using an APA. The determination of the reporting party for the transaction, the details that have to be reported and timing of reporting will be challenging. Systematic Internalisers (SIs) will have to publish quotes for equity and non-equity instruments. Tradeweb is well-positioned to deliver an effective APA service for market participants to satisfy the new pre- and post-trade transparency requirements.
MiFIR Article 28 and RTS 4 introduce the obligation to trade certain derivatives in Europe on regulated markets, MTFs or OTFs. All derivatives potentially mandated to trade are already available via Tradeweb. The Tradeweb UI will clearly indicate whether an instrument is mandated to trade and clear. Pre-trade clearing certainty checks will give assurances to the client that the trade will clear when executed on Tradeweb.
To be in a position to comply with the range of MiFID II / MiFIR requirements, market participants will need to know the “classification” of each relevant instrument before trading. Depending on instrument status, participants are able to satisfy certain obligations and gauge impact of the transparency regime. For all instruments that are in scope of MiFIR, Tradeweb will provide a “Regulatory Panel” on the trade ticket.
Fund managers often identify matching interests to buy and sell financial instruments for their various funds. When executing these interests they perform “internal crossing”; Tradeweb has developed this functionality.
Best execution requirements have existed for many years; however, with MiFID II there is now a much higher legal standard. RTS 27 and 28 put best execution further into the spotlight by specifying detailed quality
of execution reports to evidence that they have taken “all sufficient steps” to obtain the best possible result for the client. Now, more than ever, participants are searching for tools to analyse trade performance. Tradeweb's proprietary TCA tool provides in depth analysis of your trading, through real-time access via a dedicated, secure application. Tradeweb's TCA is accessed via InSite, our solution to RTS 28, which requires firms to show evidence of best execution.
Under RTS 28, investment firms executing transactions for their clients are required to make their top five execution venues public on an annual basis, based on trading volume breakdown by instrument
class. Firms will also be required to provide evidence to show the quality of execution. Firms are required to publish their first RTS 28 reports on April 30 2018, covering all 2017 trading activity. However, trading venues will only publish their first execution quality reports on June 30, 2018, covering Q1/2018. This will make it challenging for firms to produce their RTS 28 reports in April.
Tradeweb will provide all required reports for RTS 28 on our analytics platform, InSite, filling the gap before the first RTS 27 Execution Quality reports are published. InSite will provide an aggregate view of all client activity on the Tradeweb platform, including volume and trades by product. It also provides trading performance analysis, with a focus on likelihood, speed and quality of execution. We will continue to provide this data in conjunction with quarterly Tradeweb RTS 27 reports which will be published from June 30, 2018.
MiFIR Article 26.5 and RTS 22 introduce the obligation for a trading venue to report details of transactions in financial instruments traded on its platform by a firm which is not subject to the MiFID regulation. Tradeweb has developed solutions to make the provision of relevant information as easy and flexible as possible, and to limit the impact on workflow.