Agent lenders and prime brokers could be “systematic internalisers” under MiFID II

ESMA has released an updated Q&A on MiFID II transparency and market structure topics. A central issue was how to define systematic internalisers and what their responsibilities are in the market. There is no doubt that OTC derivatives players will be called out, but its possible that securities lending and repo liquidity providers would also be included. Here is our preliminary analysis.

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