The following Financial Services practice note provides comprehensive and up to date legal information covering:
BREXIT: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note. For further guidance, see Practice Note: The impact of Brexit on the MiFID II regime.
This Practice Note provides an overview of the data reporting services providers (DRSPs) regime that was introduced by the revised and recast Markets in Financial Instruments Directive (Directive 2014/65/EU) (MiFID II) and the Markets in Financial Instruments Regulation (Regulation (EU) 600/2014) (MiFIR), which came into effect on 3 January 2018. It includes a summary of the requirements for approved publication arrangements (APAs), consolidated tape providers (CTPs) and approved reporting mechanisms (ARMs), which perform an integral part of the pre- and post-trade transparency and transaction reporting regimes under MiFIR.
For more information about MiFIR and MiFID II, see Practice Notes: MiFID I, MiFID II and MiFIR—essentials and MiFID II and MiFIR—toolkit.
MiFIR requires investment firms, including systematic internalisers (SIs), to make post-trade information public through an ‘approved publication arrangement’ or ‘APA’. An APA is defined as a person authorised under MiFID II to provide the service of publishing trade reports on behalf of investment firms. A ‘consolidated tape provider’ or ‘CTP’ is a person
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For guidance on the basic features of the doctrine of estoppel and the different classifications it has been subject to, see Practice Note: Estoppel—what, when and how to plead and related content.Promissory estoppel—what is it?Where A has, by words or conduct, made to B a clear and unequivocal
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