Recital 5 of RTS 15 MiFIR sets out that charging fees in a discriminatory way so as to deter access should not be permitted. Where a trading venue has close links to a CCP, should additional considerations be taken into account when considering whether fees are discriminatory, and if so, which considerations?

Article 11 of RTS 15 MiFIR permits a trading venue to charge fees to a CCP in relation to access to the trading venue, which can include fees charged to cover one-off and ongoing costs. Can a trading venue that has already granted access to a CCP be permitted to charge new fees, whether one-off or ongoing, that were not agreed at the time of access, and if so, under which circumstances?

Article 11 of RTS 15 MiFIR permits a trading venue to charge fees to a CCP accessing the trading venue provided that it is the same schedule of fees and rebates for each CCP with regard to the same or similar financial instruments, unless a different fee schedule can be objectively justified. Where (a) a CCP has close links to a trading venue, (b) such CCP does not pass on the fees charged to it by that trading venue, and (c) the aggregated trading and clearing fees for trades executed and cleared by such trading venue and its linked CCP are therefore lower relative to the fees for the same trades cleared with non-affiliated CCPs, would the schedule of fees and rebates applicable to all CCPs accessing the trading venue be considered to be the same schedule of fees and rebates?

How to disclose cost information (in good time) to a client who places an order via telephone?

For RTS28 report, we classify the instruments using:

• the cficode of Firds to classify the instruments in Equities – Shares & Depositary Receipts, Debt instruments, Interest rates derivatives …
• the volumes of Fitrs to classify the Equities – Shares & Depositary Receipts in subassets ( (i) Tick size liquidity bands 5 and 6 (from 2000 trades per day), (ii) Tick size liquidity bands 3 and 4 (from 80 to 1999 trades per day) (iii), Tick size liquidity band 1 and 2 (from 0 to 79 trades per day))

How should we classify non – EU instruments that are not present in Firds and Fitrs?