I think there were some positives in the report but also some negatives.

The call for fair and equal treatment of data consumers by exchanges is one to be backed strongly, i.e. compliance. Unfortunately, certain exchanges are too frightened/unwilling/lazy to apply their policies evenly. This removes the level field and disadvantages smaller financial institutions.

There is a certain schizophrenia in saying there is too much concentration in certain venues leading to higher fees, i.e. listed equities, and then saying in fixed income there is too much fragmentation resulting in difficult price discovery.

While the principle of Consolidated Tapes makes sense, especially in an US because of the number of directly competing venues, the markets do not work the same way in the UK/EU.

However subscribing to the CTA can be very expensive, fees would need to be carefully looked at, or again smaller financial institutions will be at a disadvantage.

Two US CTA points:

1 It is a last price service

2 Run by the exchanges

FCA Report and Summary can be found at https://www.fca.org.uk/publications/corporate-documents/trade-data-findings

For information on our consulting services please email knharris@datacompliancellc.com

Keiren Harris 03 March 2023