So what does MiFID II finally say about the consolidated tape? If you remember the story so far, a number of Consolidated Tape Providers, or CTPs – each authorised to operate the data reporting services – are supposed to compete to provide said tape. And
if you ever wondered what the collective noun for a group of CTPs is, it appears to be ‘an authorisation’. These CTPs will be required to consolidate post-trade equities data (and later non-equities data) from all the APAs (Authorised Publication Arrangements)
and trading venues and “…consolidate it into a continuous electronic data stream and make the information available to the public as close to real time as is technically possible, on a reasonable commercial basis.”
The introduction of “all” in the latest text caught my eye. It suggests that each CTP will be covering the entire market of post-trade data, rather than fostering standardisation across CTPs that would consolidate data from a subset of APAs and venues. Mind
you, Article 67 alludes to aggregation of data published by different CTPs which kind of contradicts the ‘all’.
So the consolidated tape is indeed coming with MiFID II and all that fragmented data will be joined up again to provide a consolidated view of trade transparency. Just how the commercials will stack up, and how reasonable the cost of usage rights to that
data will be, are still for the ESMA working groups to fathom. (Would that be a ‘parliament’ or perhaps a ‘cohort’ of working groups?). And if all else fails, MiFID II still makes provision for a public procurement process to establish the tape.