SIFMA and the European Primary Dealers Association (EPDA) provide comments to the Italian Treasury in response to the Italian Treasury’s Public Consultation on the Draft Regulation on Wholesale Trading Venues for Government Bonds. SIFMA and the EPDA believe that a number of the proposed criteria for trading platforms are duplicative or “super-equivalent” of a home market’s Multilateral Trading Facility (MTF) regime and are therefore unnecessary. The proposed criteria risks undermining the Markets in Financial Instruments Directive’s (MiFID’s) core objectives of providing a level playing field in the area of securities trading (by requiring non-Italian MTFs to justify again their compliance with MiFID requirements) and discouraging competition between trading venues throughout the European Union.