It primarily covered proposed new guidance to clarify the definition of a multilateral system and questions and answers (Q&As) on the application of the general guidance to specific types of arrangements in financial markets.

The FCA published this consultation in response to findings of the Wholesale Markets Review consultation response published in March 2022, where HM Treasury recognised that there is a need for greater clarity on the types of firms which need to be authorised as a trading venue and recommended that the regulator consults on its guidance.   

CP22/18

In the joint UK Finance/International Swaps and Derivatives Association (ISDA) response to this consultation, we have highlighted the importance of the proposed guidance only capturing genuine multilateral systems.

Furthermore, we outlined that certain digitised methods aimed at achieving better investor outcomes should not be captured within the perimeter. These include order management systems (OMS) and execution management systems (EMS) which facilitate bilateral communications in a more efficient way. .

To this end, we outlined that further clarity is needed in relation to the proposed FCA guidance to ensure that digitised workflows/communication tools that enable bilateral trading are not inadvertently captured within the trading venue perimeter.

In our response we have set out further criteria and more detailed guidance that could give the market participants more clarity.

For more information, please contact avanthi.weerasinghe@ukfinance.org.uk and alastair.campbell@ukfinance.org.uk