Wednesday, April 20, 2016

The first question the trader has to answer under MIFID II is whether a bond id sufficiently liquid that it will have to trade on a venue. ESMA will make that determination issuing specific guidelines. Traders have to check these guidelines to see if they can simply provide an OTC price or if they need to trade it on a venue. Under MIFID II, if the firm's market making activity an a bond is significant and frequent, then the firm must be registered as a SI in order to commit capital to the trade. If the firm instead operates on that bond infrequently and in small sizes, then it can just provide an OTC price.

if the bond does not meet internal criteria for capital committment or the firm does not want to trade it because it does not want to become an SI then the firm act as an agent, working the order on a RM or MTF or find the other side operating as a riskless principal or matched principal. Finally, it can operate as an OTF where customer-only orders interact.

In any case, transparency obligations will be enforced, according to the liquidity bucket of the bond. the trader has to check whether the bond can avail of a transparency waiver. If yes, after a compliance check, the price can be given to the client and Bloomberg's APA will hold the release of the completed trades as per ESMA's guidelines. If not, the price provided to the client has to be made public through an APA (Approved Publication Arrangement) simultaneously. Bloomberg will be an APA.