# | Topic and Scope | Application to CME U.S. markets (DCMs) | Application to EU based investment firms trading on CME U.S. markets (DCMs) |
---|---|---|---|
1. | Transaction reporting | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
Possibly. Direct requirement on EU investment firms to report trades in (i) financial instruments traded on an EU trading venue, (ii) financial instruments where the underlying is financial instrument traded on an EU trading venue, or (iii) financial instruments where the underlying is an index or basket composed of financial instruments traded on an EU trading venue. MiFID II requirements may apply to an EU investment firm’s activity on a US DCM where (ii) or (iii) above are met. |
2. | Algorithmic trading/HFT | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM. Direct requirement applicable to EU investment firms and certain other member firms using algorithmic/HFT techniques when trading on an EU trading venue. Additional requirements apply if the firm pursues a market making strategy on an EU trading venue (as defined in the regulatory framework). |
3. | Clearing/indirect clearing obligation | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm acting as a clearing member of a US DCO. Direct requirement on EU investment firms acting as clearing members of an EU CCP regarding systems, procedures and arrangements including timing requirements on submitting and accepting trades for clearing. Indirect clearing must meet set conditions. Note: EU investment firms acting as general clearing members are also subject to requirements. These apply whether those clients are EU/non-EU and irrespective of where the cleared trades are executed. |
4. | Position limits and position management controls | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM (US position limits apply where relevant). Direct requirement on EU investment firms and other firms trading commodity derivatives on an EU trading venue or economically equivalent OTC contracts (exact scope TBC). |
5. | Position reporting | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM. Direct requirement on EU investment firms and other firms trading commodity derivatives on an EU trading venue or economically equivalent OTC contracts. |
6. | Pre-trade and post trade transparency (relevant for package transactions, incl. EFRPs and Large In Scale (LIS), i.e. blocks) | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. Requirement only for EU venues. Note: EU investment firms may have transparency obligations if they enter into transactions that are traded on a trading venue outside of the rule of the trading venue. |
7. | Direct Electronic Access/ Sponsored Access | No Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM. Direct requirement on EU investment firms and certain other members who provide DEA/sponsored access to clients for trading on an EU trading venue. |
8. | Clock synchronisation | No. Applicable only to operators of EU trading venues. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM. Direct requirement on EU investment firms trading on an EU trading venue. |
9. | System resilience and circuit breakers (incl. market making) | No. Applicable only to operators of EU trading venues. US requirements apply to CME’s DCM markets. |
No. MiFID II requirements do not apply to an EU investment firm’s activity on a US DCM. Direct requirement on firms trading on an EU trading venue. Additional requirements apply if the firm pursues a market making strategy on an EU trading venue (as defined in the regulatory framework). |
For more information about this regulatory reform:
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