The Association for Financial Markets in Europe (AFME), with support from PwC and Linklaters,has todaypublished anewreport,whichprovidesapracticalguide forEuropean authorities andMember Stateslooking to introduceanewhybridrecapitalisation instrumentthatcouldhelp provide fundingforsmaller corporatespost-Covid. The report, “Introducing aNewHybridRecapitalisationInstrument forSmaller EUCorporates”builds onanearlier January reportwhich examinedtherecapitalisationneeds ofsmallerEUhybrid equityinstrument could enable a greater number of SMEsto gain access to equity-like funding without relinquishing control of theirorganisationcorporates following the pandemicand foundthat a– one of theirchief concerns. However,sucha solution needs to be tailored tothe localaccounting,legal framework,andtax and insolvency treatmentin individual EU Member States,to achieve thekey attributesnecessary for creating an instrument which meets the needs of both investors and corporate issuers. Existingdomestic frameworks inGermany, France, Italy, Spain and the Netherlandsare presentedasexampleswhichofficials inother Member Statescan refertoindevelopingstructures which work in their own countriesand preferably at EU-widelevel. Adam Farkas, Chief Executive of AFME, said:“As economic conditions graduallyimprove,it is vital that smaller unlisted companies and midcapsin the EUwith the potential to drive economic growth have access to ample fresh capital to invest in innovation and their future growth. Alternative types and sources of funding will berequired to meet this challenge. “While some EUMemberStates – including France, Spain and the Netherlands – have recently launched nationaldebt-focusedschemes and instruments to support company recapitalisation,AFMEcontinuesto see significant value in the development of an EU-wide recapitalisation instrument frameworkthat could be rolled out across variousMemberStates.” Thereport presents the following analysis: An overview of the key hybrid instrument attributesrequired to achieve the desired equity accounting, taxdeductibilityand insolvency treatment. A summary of state aid considerationsthat are likely to be taken into account in assessingthe introduction of suchequity-accountedhybrid instruments for the purposes of compliance with EU state aid requirements. A generic sample term sheetoutlining the proposed instrument features which can be used as a reference fordiscussion with officials, investors and mid-cap/SME corporate issuers. AFMEbelievesthe report will provide a useful reference forpolicy makers and key stakeholdersin order to bringthe idea of a new hybrid instrument for SMEsto reality and that officials, corporates and investors can continue to work together to design solutions adjusted to the needsof companies seeking investment capital in the phase of economic recovery. –Ends – Notes: This report followsAFME’s January2021report,whichestimated that Europe could face a funding gap of €450-600bn in equity and hybrid capital to prevent business defaults with the gradual reduction of state support measures.

The Association for Financial Markets in Europe (AFME) has today announced the relocation of two staff to Germany and a new office address in Frankfurt. The office will be staffed by Richard Middleton, Managing Director, who will focus on developing stakeholder relationships with local trade bodies and regulatory and supervisory authorities in Frankfurt, and Arved Kolle, Associate Director, who will be responsible for building up relationships in Berlin and liaising with the European Central Bank. Adam Farkas, AFME Chief Executive, said: “We have taken the decision to expand our Frankfurt office this year to strengthen our presence both in Germany and the EU more widely as capital markets become more important than ever to aid the post-pandemic recovery and the financing of the sustainable and digital transformation.” AFME is the European trade association for the leading European and global investment banks and other significant capital market players, shaping policy in Europe’s capital markets. AFME has been on the ground in Frankfurt since 2017 and has offices in Brussels and London. Find out more about AFME’s work in Germany here. – Ends –

The Association for Financial Markets in Europe (AFME) has today published its quarterly Equities Data Report. The report provides an update on the performance of the equity market in Europe in activities such as primary issuance, Mergers and Acquisitions (M&A), equity liquidity structure, and market valuations. Key findings include: Equity issuances on European exchanges accumulated an increase of 39% in the first three quarters of 2021 compared to the same period of 2020. However, following two exceptionally robust quarters, equity capital raising decelerated in 3Q 2021 to levels closer to historic volumes, with a decline of -46% QoQ. IPOs for €52.8bn have taken place in the first three quarters of 2021, almost 5 times the amount issued in the same period of 2020. SPAC IPOs represented 11% of total European IPOs in Q3 2021, a decline from 15% in Q2 2021. Domestic market capitalisation of European listed shares stood at €16.8tn at the end of September 2021, a 18% increase from €14.2 at the end of 2020. European[1] Completed Mergers and Acquisitions (M&A) of European companies totalled €829bn in the first three quarters of 2021 a 60% increase from the amount completed in the same period of 2021 (€519bn). This represents the highest YtD volume since 2007. The amount of announced M&A totalled €941bn in Q1-Q3 2021, a 81% increase from the same period of 2020. De-SPAC acquisitions represented 8% of the total announced European M&A in Q3 2021 (5% in Q2 2021). 86% of the announced SPAC acquisitions of European companies during Q1-Q3 2021 are De-SPACs of US-headquartered SPACs. These European companies will be effectively listed on US exchanges via their SPAC parent company. ​ Average daily equity trading activity on European main markets and MTFs stood at €74.6bn in Q1-Q3 2021, 6% below the average daily observed in Q1-Q3 2020. Double Volume Cap (DVC) update: The number of instruments suspended under the DVC has recently increased to 380 at the EU or trading venue level as of October 2021 (from 205 in Dec-20). European trading volume by trading mechanism The report also shows that the majority of equity trading in Europe (82%) takes place on venues[i]. A much smaller share takes place off-venue on alternative trading mechanisms known as systematic internalisers[ii] (SIs) which account for 10% of trading, and over the counter (OTC), which accounts for 8%. The updated figures, sourced from BigXYT, continue to confirm the findings AFME published in June with consultancy, Oxera showing that when technical trades are filtered out of the full universe of reported equity transactions, a true picture of economic trading activity is revealed. While technical trades, such as those undertaken out of hours or that are not price-forming, are informative from a supervisory perspective, they have no relevance when conducting an analysis of the trading and liquidity landscape. AFME’s quarterly data report will continue to track the share of European trading volume by trading mechanism going forward. – Ends –

A new report by the Global Financial Markets Association (GFMA) and Boston Consulting Group (BCG) titled, “Unlocking the Potential of Carbon Markets to Achieve Global Net Zero”, finds that close to 80% of greenhouse gas emissions are not covered by regulated carbon pricing today. In order to meet the Paris Agreement goals, price levels need to increase to an estimated $50-150/tonne average by 2030 from the current global average of <$5/tonne. To do this, the report highlights the role and importance of both compliance and voluntary carbon markets (a description of which can be found in the below graphic) to the low-carbon transition. Steve Ashley, Nomura Head of Wholesale Division and Chairman of GFMA, said: “Effective carbon pricing in the economy is one of the strongest tools to drive changed outcomes, treating GHG emissions as a time limited resource. Compliance and voluntary carbon markets can play a significant and complementary role and rapid action is required across policymakers, regulators, banks and capital markets participants to ensure the right incentives to economic decision making.” Kenneth E. Bentsen, Jr., CEO of GFMA and president and CEO of SIFMA, said:“Greenhouse gas emissions have increased by 50% over the last 30 years, with the world having warmed by approximately 1°C and an increase of 1.5°C expected within the next few decades. To limit a further temperature rise, a rapid scaling of carbon markets is required in order to mobilize an estimated $100—150+ trillion investment needed across sectors and regions[1].” Roy Choudhury, Managing Director and Partner at BCG, said: “With a 300–500 Gt of total carbon budget left, the next three decades must see a swift decline in emissions down from the current ~50 GtCO2e per annum to a global Net Zero on GHG emissions. Levers will need to be pulled, including a rapid scaling of carbon markets, both in geographic and sectoral coverage, and in ambition/rate of decarbonization.” The report identifies key data and recommendations for policymakers, market participants, and other key stakeholders to scale deep and liquid carbon markets for improved global and regional pricing effectiveness to significantly accelerate carbon reduction. The report also highlights the current challenges which the public and private sector need to overcome in order to prioritize the urgent action required to scale carbon markets in the near-term. These challenges include: Further scaling and enhancement of regulated policy-driven carbon pricing mechanisms such as Emissions Trading Systems (ETSs). Despite almost 200 countries having signed the Paris Agreement, the operationalization of this 1.5°C ambition into policy measures, such as ETS initiatives, is insufficient in terms of geographic scope, sectoral coverage, and decarbonization rates. Close to 80% of global greenhouse gas emissions are still not covered by regulated carbon pricing today. Price levels also need to capture true cost of emissions, from the current global average of <$5/tCO2 to an estimated $50–150/tCO2 average by 2030. Conservative estimates suggest a need to scale ETSs from ~$170 bn today to $1 tn+ in absolute size before 2030 to achieve the 1.5°C ambition. Developing clear role of the Voluntary Carbon Markets (1) as a transitionary mechanism, until regulated mechanisms take over and ultimately scale down with reducing emissions, (2) as a long-term global marketplace for carbon removals for neutralizing residual emissions and pursuing negative emissions, and (3) as a complementary mechanism for entities to compensate for their emissions while they pursue decarbonization in their value chains. To strengthen trust in the voluntary carbon markets, and to enable it to grow from the current scale of <0.5% global emissions, it is critical to develop stringent and transparent baselining and Measurement, Reporting and Verification (MRV) standards to ensure verifiable “additional” emissions reductions; a regular process to make standards increasingly stringent to ensure that VCM projects maintain additionality. Encouraging greater interoperability driven by the public sector The interoperability between carbon markets is insufficient to meet the demands of investment required to address climate risks. Greater interoperability needs to be driven: (1) between ETSs where rates of decarbonization are aligned, and (2) between ETSs and the voluntary carbon markets through tightly controlled mechanisms—stringent MRV and limits on eligibility and quantity to ensure additionality—would serve to grow the carbon markets and drive additional co-benefits regionally and globally. At present carbon markets are very fragmented, which holds back the necessary market growth to meet the G7 and Paris Agreement objectives. The report recommends that banking and capital markets firms can help develop carbon markets through capabilities and product offerings that help market participants in their compliance, decarbonization, risk management, and investment needs. Ultimately, the private sector’s role complements the actions of the public sector in addressing the challenges identified within this report. – Ends – AFME Rebecca Hansford Head of Media Relations [email protected] +44 (0)20 3828 2693 ASIFMA Corliss Ruggles Head of Communications [email protected] 852 9359 6996 SIFMA Katrina Cavalli Managing Director, Public Affairs [email protected] 212.313.1181About AFME: [1] As highlighted in GFMA and BCG’s previous publication “Climate Finance Markets and the Real Economy https://www.gfma.org/policies-resources/gfma-and-bcg-report-on-climate-finance-markets-and-the-real-economy/

In response to the publication today by the European Commission (EC) of the CRR3 proposal,which implements the final December 2017 Basel III rules and concludes the post 2008  financial crisis regulatory repair programme,Michael Lever, Head of Prudential Regulation,at AFMEsaid: “European banks have raised hundreds of billions in equity capital since the financial crisis,resulting in record capital levels andhighresilience as evidenced by therecentresults oftheexceptionally severe European stress test. It will be important,therefore,that the co-legislators adhere to the Basel standard setters’ commitment to avoid any significant further increases in minimum capital requirements. “Unfortunately,severalimpact studies suggest that this is unlikely to be the case with the largest European banks facingmaterial increases to their capital requirements,especiallyonceallrequired capital buffers, such asbanks’managementbuffers,are included.This could have negative consequences for lending and broader economic activityifbalance sheet growth is constrained to conserve capital. “We welcome the Commission’s intention to extend the implementation date for the proposal until 1 January 2025 and strongly recommend that this is globally agreed on to ensure the simultaneous adoption of all proposals. We also supportthesuggestions to maintain limited European market specificities while remaining faithful to the Basel principlesandproposedimprovements tothe treatmentsofexposures to unrated corporates and low risk real estate lending.However, these are unlikely to go far enough to avoidmaterialcapital increases which risk undermining banks’ ability to support their customers’ financing needs as they recover from the impact of theCovid-19 pandemic.  Further adjustments to the proposals are therefore likely to be required,including changes to the calibration of the Output Floor-the market impact of which is likely to be felt from 2025,despite its planned five-year phase-in-and to limit the impact of this measure on specific asset classes and business lines. “The Commission is also proposing enhancements to the regime relating to the regulation and supervision of third country branches to address diverging practices and overlapping requirements. AFME supports proposals to harmonise current practices to ensure appropriate visibility and strengthen international cooperation arrangements. However,such arrangements should place a high degree of reliance on home state supervisory regimes and avoid any mandatory requirement for local subsidiarisation without a full understanding of the reasons for doing so and only then where it is not possible to reach alternative supervisory solutions.” –Ends –

Press releaseavailable inEnglish,French,German,Italian,Spanish. Individual country analysis available forUK, France,Germany,Italy,Spain. Record levels of capital markets funding supported EU businesses in the first half of 2021, reflecting significant recapitalisation needs in response to the pandemic and favourable conditions for raising capital; Capital markets funding to European SMEs grew at a record rate, with the increase predominantly driven by venture capital and private equity growth funds; In spite of these record growth rates, absolute levels of market-based financing remain below those of other major jurisdictions. Additionally, securitisation issuance levels continued to decline; The increases observed may be influenced by the extraordinary conditions of the past year, public support programmes and other factors; ESG issuance in Europe continues to expand in Europe, up 69% compared to 2020; Inefficient withholding tax collection procedures continue to be a barrier to cross-border integration in EU securities markets. European capital markets activity has surged in the past year as businesses emerging from the pandemic have sought to raise capital according to a report published today by the Association for Financial Markets in Europe (AFME) in collaboration with 10 other European and international organisations. The fourth edition of the “Capital Markets Union Key Performance Indicators” report tracks how individual Member States have progressed against 8 key performance indicators on metrics such as access to market finance, levels of bank lending, transition to sustainable finance and a supportive fintech environment. Adam Farkas, Chief Executive of AFME, said: “This year, Europe’s capital markets have remained resilient and continued to support businesses, with our report showing a surge in funding raised through the markets. However, there is no room for complacency: a structural and pandemic-induced “equity gap” remains and equity-type finance still needs to be expanded in Europe. It also remains to be seen to what extent these record market-based financing levels will persist, or whether they are a temporary result of the extraordinary support measures of the past year. “Our report also shows there is still much work to do on enhancing the provision of risk capital to meet themajorlong-terminvestment needs of thegreen and digital transitions, improving the functioning of securitisation and tackling long-standing frictions in EU capital markets, such as inefficient withholding tax procedures. In this respect, the Capital Markets Union project remains vital for the single market and must be implemented fully.” Key findings: European primary capital markets continued to expand during H1 2021 for the third consecutive year, with the proportion of markets-based funding for EU corporates rising to 16.8%; Many European SMEs have benefited from funding availability from private markets. Europe is the fastest-growing major region by private capital investment with investment in European SMEs growing by 2.4 times year-on-year in the first half of 2021. European households have increased the amount of capital markets savings over the last 2 years, although this is predominantly driven by valuation gains of existing products. Countries that entered the COVID-19 crisis with low capital markets savings have increased the most their bank deposit holdings, which suggests that investment vehicles and household incentives could be enhanced in some Member States; The depth of the EU securitisation market has declined over the last 3 years. Unlike in the US, the proportion of EU securitised products and loan disposals relative to total loans outstanding has consistently declined over the last 3 years. This remains an area of concern as securitisation facilitates risk transfer and enables the banking sector to transform loans into tradeable securities, thereby allowing banks to continue lending to corporates; The EU continued to improve the local FinTech ecosystem with the launch of new regulatory sandboxes in Austria, Spain, Hungary, and Greece over the last year. The EU has also benefitted from a record increase in funding which has also resulted in a rapid surge in the number and valuation of FinTech unicorns (i.e. growth companies valued above $1bn); EU ESG debt markets have expanded rapidly during H1 2021, with total issuance of ESG-labelled bonds reaching EUR 201.4 bn, representing 19.6% of total EU bond issuance during the first half of 2021; As a special feature of this edition, we have included an analysis of the current variations between Member States in their procedures for withholding tax relief, which have a significant negative impact on cross-border investment, cost of capital and GDP. In 10 of the 27 EU Member States there is a lack of a relief-at-source mechanism which frequently results in long delays in tax reclaim reducing investor returns. The report was authored by AFME with the support of the Climate Bonds Initiative (CBI), as well as European trade associations representing: business angels (BAE, EBAN), fund and asset management (EFAMA), crowdfunding (ECN), retail and institutional investors (European Investors), stock exchanges (FESE), venture capital and private equity (Invest Europe), private credit and direct lending (ACC) and pension funds (Pensions Europe). – Ends –

Following the publication of the UK Government’s Roadmap on Greening Finance, the Association for Financial Markets in Europe (AFME) issued the following statement: AFME welcomes today’s announcements and the publication of a detailed roadmap for sustainable finance, including the implementation of integrated sustainability disclosure requirements and the development of a Green Taxonomy in the UK. The financial services sector plays a vital role in supporting the transition to net zero. It is important to put in place a clear framework for corporate sustainability reporting and to provide clarity and consistency of classification of environmentally sustainable investments in order to enable investors to effectively and efficiently allocate capital in support of the transition. Oliver Moullin, Managing Director for Sustainable Finance, said “Today’s announcements provide important details on the UK’s implementation of its roadmap for greening finance. The building blocks of sustainability disclosures and the development of a Green Taxonomy should form key enablers of the financial sector’s role in mobilising capital to support the transition to Net Zero.” As the UK proceeds with implementing its roadmap, AFME strongly supports the UK Government continuing to seek progress at the international level to maximise international consistency of approaches to taxonomies and reporting standards. Well designed and appropriately sequenced Sustainability Disclosure Requirements are essential to ensure that financial institutions and investors have the necessary data to allocate capital to support transition plans, and for their own disclosures and risk management. Improved quality and consistency of ESG data is also a vital tool to help combat greenwashing and improve the quality and comparability of ESG ratings. In developing a Green Taxonomy, the Government should aim to minimize fragmentation and support global capital markets by reflecting on experiences with the EU Taxonomy as well as ongoing work by the International Platform on Sustainable Finance. It will also be important to take into account the recommendations of the Global Financial Markets Association (GFMA) Global Guiding Principles for Developing Climate Finance Taxonomies[1]. Alongside sustainability disclosures and the development of a Green Taxonomy, businesses, banks and investors need a clear roadmap for the economy-wide transition to a low carbon economy, enabling them to design and assess credible and effective strategies in support of the transition. -ENDS – GFMA Global Guiding Principles for Developing Climate Finance Taxonomies, available at https://www.gfma.org/wp-content/uploads/2021/06/global-principles-for-climate-taxonomy.pdf

The Association for Financial Markets in Europe (AFME) has today published a paper investigating the impact of the pandemic on the use of the buffer framework and recommending improvements to its viability. During the Covid-19 pandemic, central banks allowed banks to draw on their capital buffers to ensure lending to the economy continued and to avoid a crisis. This is the first time that the use of capital buffers has been called into action since the framework was established as part of the reforms post the financial crisis. AFME’s paper shows that despite central banks encouraging banks to use their buffers, very few actually dipped into them for a number of reasons, primarily because of the stigma associated with triggering the Maximum Distributable Amount (MDA) - the capital level that a financial institution must meet in order to be able to make distributions such as dividend and remuneration pay-outs. In light of this, the report recommends: a rebalancing of the Capital Conservation buffer and Countercyclical Capital buffer; better coordinated supervisory communication; and a more transparent, rules-based MDA framework. Constance Usherwood, Director of Prudential Regulation, at AFME said: “As we emerge from the pandemic it is important so see what lessons can be drawn from the way in which regulators expected banks to make use of the capital buffer framework and how effective this was. While the industry welcomes the supervisory measures which were taken, supporting banks to continue lending, there is evidence to suggest that in practice, banks did not want to draw on their buffers due to negative interactions with other parts of the macroprudential framework, such as MDA triggers. “We think the usability of buffers could be improved by reducing stigma from breaching MDA triggers through a rebalancing between the Capital Conservation buffer and the Countercyclical Capital buffer. In addition, there is room for improved and coordinated supervisory communication and a more transparent, rules-based MDA framework.” The need to make buffers more releasable has been recognised by both the FSB and the BCBS in their assessments of the policy measures taken during the pandemic. In the FSB’s interim report to the , which is soon to be followed up with a final report, they suggest “it may be beneficial to consider whether there is sufficient releasable capital in place to address future systemic shocks”. The European Commission has also recently mandated the EBA to review the macro-prudential framework in advance of a legislative review in 2022, which will consider the overall design of the buffer framework. – Ends –

Ahead of the MIFIR Review, the Association for Financial Markets in Europe (AFME) has today published its position on a Consolidated Tape in Europe. Adam Farkas, Chief Executive at AFME, said: “As the MiFIR Review fast approaches, all corners of the financial markets industry are articulating their needs for a consolidated tape in Europe. From AFME’s members’ perspective the use case is clear: in equities markets we need a real-time consolidated tape in Europe that provides access for all investors to help build deeper and more open capital markets in Europe. “An equity real-time consolidated tape would cut costs and democratise access to all retail investors across the EU, contributing to the creation of a truly pan-European market. This technological solution would help advance the objectives of the Capital Markets Union, while ensuring that interconnected national ecosystems continue to serve local communities. “This is also why having diverse market structure is vital, providing investor choice and competitiveness. The establishment of a consolidated tape should not in any way interfere with the existing market structure in the EU – policy makers need to protect market diversity which is the backbone of healthy, resilient, and competitive European financial markets. In this respect, a consolidated tape would also aid with reducing the market power of trading venues when selling real-time, extremely expensive, post-trade data. “Now is the time to address Europe’s lack of competitiveness with regards to having a single price comparison tool for investors across Europe. However, it will be important to get the balance right, so that it makes sense for investors at the heart of the tape, without damaging market structure.” In order for a Consolidated Tape (CT) to work, AFME members recommend: The equity CT must be real-time – there is no business case for a delayed tape, given that the legal framework already requires the provision of market data, free of charge, 15 minutes after publication. Conversely, an equity real time tape offers a number of benefits. Data quality should be addressed alongside the development of a CT – the implementation of the post-trade transparency regimes under MiFID II identified a number of data quality issues relating to SI and OTC post-trade reporting, particularly the treatment of non-addressable/non-price forming trades which should be excluded for the purposes of post-trade transparency. The bond CT needs to ensure committed liquidity providers are not exposed to undue risk by not publishing post-trade details until after the deferral period has expired. MiFID II introduced deferrals because it was recognised that real time post-trade transparency can expose committed liquidity providers to undue risks, especially when trading in illiquid instruments or transactions above a certain size, hence diminishing the liquidity available to corporates and investors. The establishment of a CT must not impact the well-established market structure framework in Europe The cost of accessing the CT should be as low as possible in order to democratise market data within Europe and ensure healthy, competitive markets Mandatory data contribution to the CT – trading venues, APAs and systematic internalisers (SIs) should be required to provide market data, free of charge, to the CTP. Without this approach, costs will ultimately be passed on end users and this could limit the number of firms consuming data, reducing the commercial incentive for the emergence of a single consolidated tape provider. No mandatory consumption of the CT – market participants should not be forced to consume the CT as, in many cases, this will mean that firms are forced to pay for the same data via direct feeds and via the CT (i.e. paying for the same data twice). Instead, a CT should be appropriately constructed so that it provides an offering that is economically attractive to market data users. This will ensure the continued success of a CT. There should be a single CTP for each asset class– without a single provider, the risk of multiple providers emerging with potentially different or overlapping product scopes may defeat the purpose of having a truly consolidated view of the market and increase costs to consumers. – Ends –

In response to ESMA’s recent public consultation, dated 1 October, calling for evidence on retail investor protection issues, such as payment for order flow (PFOF), the Association for Financial Markets in Europe (AFME) has issued the following statement: AFME agrees that payment for order flow (PFOF) models are unlikely to be compatible with existing MiFID II rules on avoiding conflicts of interests and ensuring best execution outcomes for clients. AFME also agrees that a review of PFOF models should be undertaken to encourage greater supervisory convergence among EU Member States. The safeguards put in place by MiFID II rules ensure that investors are suitably protected and that the primary goal of investment firms is to achieve best execution outcomes for their clients. Clients and regulators should be able to test claims from retail brokers that they are offering best execution through any liquidity provider which pays for order flow. We note that a consolidated tape showing prevailing available prices at the time of the receipt of a client order would assist in verifying these claims by reviewing a retail broker’s executions in aggregate. – Ends – Notes to Editors: MiFID II has strict requirements for investment firms to manage conflicts of interest. Firms are required to take all appropriate steps to identify and prevent or manage any conflicts of interest “between themselves… and their clients… including those caused by the receipt of inducements from third parties”. MiFID II also explicitly states that firms need to prevent conflicts of interest in the first instance and to rely on disclosure only as a last resort. These requirements are set out under Articles 23, 24 and 27 within MiFID II which cover conflicts of interest, best execution and inducements respectively. Some National Competent Authorities have commented on payment for order flow including the AMF[1] and FCA[2] agreeing that MiFID rules prevent conflicts of interest and ensure best execution for clients [1] Speech by Robert Ophele (AMF Chairman), March 2021 – link here [2] FCA supervisory guidance, April 2019 – link here