How should permission to trade in a closed period, which may be granted in certain circumstances to PDRMs in accordance with Article 19(12) of MAR, be considered in the context of Article 14 of MAR?

(a) Once Article 38 of CSDR applies (i.e. after the CSD has been authorised), do participants have a phase-in period after authorisation of the CSD to offer all clients the level of protection envisaged in Article 38(5) or should they be ready to offer the envisaged accounts as of the date on which the CSD is authorised?

(b) In accordance with Article 38(5) of CSDR, should all clients (existing and new) be offered the choice between omnibus client segregation and individual client segregation, and be informed of the costs and risks associated with each option, or just new clients?

(c) Are there specific account segregation requirements in the context of links between an EU CSD and a TC-CSD?
(d) Under Article 38(4) of CSDR, can a CSD maintain different types of securities accounts enabling participants to segregate the securities of any of the participants’ clients (‘individual client segregation’), such as securities accounts with or without the identification of the participant’s client at the CSD level?
(e) When a CSD offers different types of individually segregated securities accounts (such as securities accounts with, and securities accounts without the identification of the participant’s client at the CSD level), should the CSD participants offer in turn the same types of individually segregated securities accounts to their clients?

How should transactions be transaction reported where portfolio management has been outsourced?

Does a firm need to be authorised as an investment firm under MiFID II to provide DEA to an EU trading venue?

Can DEA clients accessing an EU trading venue through sub-delegated DEA benefit from the exemption offered under Article 2(1)(d) of MiFID II?