To be compliant with MiFID II rules, and specifically the order record keeping requirement known as “RTS 24”, trading venues will have to record considerable amounts of data throughout the trading day. This presents Bats and other trading venues and their users with a challenge: how to capture and store sensitive data in a way that provides participants and their clients with peace of mind and does not damage the efficiency of the order execution process.
Bats has consulted extensively with market participants and other trading venues across asset classes to develop a solution that it believes can be adopted as a standard. This solution captures short form IDs on orders and supplements them with a mapping file containing the underlying data, which can be provided at another time. This mapping file is stored securely until a regulator requires the complete order records.
David Howson, chief operating officer at Bats Europe, says: “In preparation for MiFID II, we’ve been working closely with the industry to standardise the manner in which investment firms supply required data to our venues. We believe our approach to the record-keeping requirements in MiFID II is a low-impact, secure method and we encourage other venues to adopt this approach to create harmonisation across the industry.”
Howson adds: “The RTS 24 requirements have been one of the most significant areas of development for Bats as it relates to MiFID II. We have put a lot of time and consideration into the development of this approach and we’re pleased to roll-out testing of the solution, enabling our participants to test the process for more than 16 months prior to MiFID II coming into effect on 3 January 2018.”
Separately, trading venue organisational requirements of MiFID II require Bats to provide a facility to support participant testing of algorithms. While Bats already provides a number of fully functional customer test environments, Bats is enhancing these through the simulation of a number of scenarios, including disorderly market conditions.
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