The Bond Market Association (TBMA)* provide comments to the Forum of European Securities Commissions (FESCO) on the FESCO consultation paper, Proposed Standards for Alternative Trading Systems (11 June 2011).  TBMA strongly believes that it is inappropriate for FESCO to press ahead with its own proposals relating to alternative trading systems (ATFs), given the likely overlap with the proposed changes to the Investment Service Directive (ISD).  TBMA notes that any changes to the regulation of trading systems should be addressed as part of the ISD review.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.