OpenLobby.EU
Explore

Etrading Software (Netherlands) BV

ETS

Etrading Software is the global provider of technology-led solutions designed to assist public authorities, standards bodies, financial institutions and industry initiatives address highly complex and constantly evolving market and regulatory challenges.

Lobbying Activity

Meeting with Tatyana Panova (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

29 Sept 2025 · EU and UK Consolidated tape

Response to Supervisory fees for consolidated tape providers

10 Mar 2025

As a bidder for the EU Bond Consolidated tape, we are broadly supportive of the amendments to MiFIR which have provided a regulatory environment to better support and encourage the development of an EU Consolidated Tape per asset class, The viability of the Consolidated Tape will be contingent on several factors, not all of which are within the purview of ESMA or the European Commission. However, the reliability, predictability and transparency of costs over the five-year mandate is a key component in the design of the Consolidated Tape Providers (CTPs) business model and fee structure, helping ensure the viability and competitiveness of the CT throughout the mandate. Therefore, we are supportive of the initial fixed supervisory fee model given that it provides certainty to both ESMA and the CTP. For subsequent years, we note that the turnover based model relies on external variables outside the control of the CTP, namely ESMAs supervision budget and the revenue of other CTPs. These external variables introduce significant uncertainty when estimating future supervisory fees for incorporation into the CTPs business model. We recommend providing early clarification of ESMAs anticipated supervision budget for the duration of the contract, and how these fees are affected by the number of CTPs being supervised.
Read full response

Response to Applying a unique identifier for public transparency of OTC derivatives

9 Jul 2024

Etrading Software Netherlands B.V. (ETS) designs, builds and operates technology solutions for the global capital markets. We operate regulatory-led capital market infrastructures that combine robust governance and transparency with high operational efficiency. We also operate market-led infrastructures that provide automated solutions to our clients for previously manual processes. Our focus on governance, efficiency and automation has resulted in our solutions being sought after by the overseers and operators of global capital markets. ETS is the declared bidder for the bond and derivative consolidated tapes (CT) in the EU. From this perspective, ETS believes that an important part of the newly amended and rationalised OTC derivative transparency regime pursuant to the MiFIR Review should aim at significantly improving OTC derivative reference data. We believe these reference data modifications are a prerequisite for a successful derivative CT. ETS believes that the targeted modification of the OTC ISIN (while embedding the UPI) as proposed in the Delegated Act is the optimal approach for transparency in terms of the desired outcome, namely: 1.) Ensuring high quality reference data 2.) implementation of the UPI (ISO 4914) in the EU to ensure cross-jurisdictional OTC derivative transparency alignment, 3.) lowest costs, and 4.) least operational impact for market participants and competent authorities. As such, ETS support the DAs proposal to modify and enhance the current ISIN-based approach for OTC derivative reference data. By allowing a price to be attached to a single identifier without needing additional data elements, the consumption of the CT data is simplified and increases reference data quality from the outset. ETS supports the modification of the ISIN to remove the daily expiry data for the same reason as it simplifies consumption of the tape data and increases data quality by halting the proliferation of ISINs on a daily basis for benchmark-based. Modification of ISIN as proposed in the DA increases the precision of the ISIN to ensure non-standard swaps do not have the same ISIN as a swap trading on market conventions, because these have different liquidity and price profiles. ETS also support the proposal for different ISINs to be allocated for spot starting swaps vs forward starting swaps. However, the existing proposal means the same ISIN is allocated to multiple forward starting swaps. This means that it is not possible to distinguish between a 5Y 5Y forward swap and a 5Y 10Y forward starting swap. In order to ensure the right levels of consistency and reference data quality for the CT, ETS believes the DA should be modified to ensure a different ISIN is allocated for such a use case. This could be achieved, by way of example, through the inclusion of whole-year forward starting term as an attribute of the ISIN, in addition to a forward term indicator.
Read full response