On September 24, 2021, ISDA submitted a response to HM Treasury on the Wholesale Markets Review (WMR). The WMR is a welcome opportunity to tailor the UK’s revised Markets in Financial Instruments Directive (MIFID II)/Markets in Financial Instruments Regulation (MIFIR) framework to the UK market, and ISDA members support a large majority of the proposals. However, ISDA has proposed several key changes, including recalibrating the transparency regime for derivatives markets, with the aim of achieving greater, more meaningful transparency in the UK. ISDA welcomes HM Treasury’s proposals that all post-trade risk reduction services should be exempt from the derivatives trading obligation and the scope of the derivatives trading obligation and clearing obligation should be realigned. ISDA also welcomes HM Treasury’s proposals to simplify and improve the systematic internalizer regime.

HM Treasury and the UK Financial Conduct Authority will discuss the next steps at ISDA’s MIFID II conference on September 29.