The Swedish Investment Fund Association (“SIFA”) believes that transparency is essential for a well-functioning non-equity market. We have recently experienced that even though the market could be called fairly ok, at best, in non-distressed markets, it does not work in distressed situations. We believe that now there could be a window of opportunity to make improvements in the transparency and the market functioning.
Overall SIFA supports the ESMA initiative to enhance transparency by adjusting limits and waivers and also working towards greater supervisory convergence.
Even though pre-trade transparency can be seen separate from post-trade transparency they are interconnected. With the existing extensive deferral regime for post-trade, pre-trade information could be used as a source in for example valuation of bonds. Hence a better functioning pre trade transparency could for example help to mitigate the problem with late/non-existing post-trade data.