By David Calligan and Karen Butler, King & Wood Mallesons London

捕获MiFID II will introduce a comprehensive regulatory regime governing direct electronic access (DEA) to trading venues (regulated markets, multilateral trading facilities and organised trading facilities).

What is DEA?

There are two types of DEA: direct market access (DMA) and sponsored access (SA). DMA is an arrangement where a member of a trading venue allows a client to use its trading code so the client can electronically transmit orders in financial instruments directly to the trading venue; such arrangements involve the use by the client of the member’s infrastructure to transmit the orders. SA does not involve the use by the client of the member’s infrastructure. SA clients are seen by ESMA as having a higher risk trading flow as it does not go via a DMA provider’s trading system; instead, SA clients’ order flow goes through validation checks provided by the trading venue and is monitored by the member of the trading venue which sponsors the access. Accordingly, a trading venue has an obligation to authorise the provision of SA on a case by case basis.

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