Many Dutch trading firms use fast, moden technology, just like many banks, brokers and asset managers. This makes it possible to hedge trading positions and control risk more accurately. It also helps to provide more accurate better prices, which has lead to more cost efficient trading, to the benefit of investors, such as pension funds.

Exchanges and trading firms are assessing developments around the speed of trading in relation to the provision of liquidity. It is not yet clear whether slowing down trading would mean an improvement for investors.

• In this paper we discuss the possible advantages and disadvantages of 'speed bumps' to limit the speed pf trading .
• And in this paper we respond to the FCA Occasional Paper “Quantifying the High-Frequency Trading“ Arms Race ”.

Contrary to the suggestion that trading firms left the market during the Flash Crash of 2010, causing the trading to dry up, most Dutch trading firms did not stop trading during this crash (which lasted a few-minutes), but continued to provide liquidity. These firms thus contributed to the price formation process (with the exception of some instruments on which no recent data was available). Trading firms will continue to do so in the future, also when volatility rises.

After the Flash Crash, various protective measures have been taken to reduce the risk of a crash, such as the introduction of 'circuit breakers ' (MiFID). The fact that the markets kept going without major disruptions during the very volatile period in March 2020 is an indication that these measures are functioning properly.

• In this consultation response our position on the remuneration policy of trading firms has been set out. Members of APT consider it important to explain the remuneration policy and its societal function, as proposed in the Legislative Proposal on Further Remuneration Measures for the Financial Sector.

• In this consultation response we give our response to the proposed implementation of the European IFD Directive investment firms in the Financial Supervision Act.

In the following consultation responses, we identified areas for improvement in the market structure and the MiFID framework and set out our position regarding the costs of market data:

• APT Reaction the ESMA Consultation Paper MiFID II / MiFIR review report on the development in prices for pre- and posttrade data and on the consolidated tape for equity instruments (5 September 2019)
• APT Reaction to the ESMA Consultation Paper on MiFID II / MiFIR review report on the transparency regime for equity and equitylike instruments, the DVC and the trading obligations for shares (17 March 2020)
• APT Response to the European Commission’s Public consultation on the review of the MiFID II / MiFIR framework (15 May 2020)
• APT Response to the ESMA Consultation Paper on the MiFID II / MiFIR review report on the transparency regime for non-equity instruments and the trading obligation for derivatives (12 June 2020)
• In this article in Het Financieele Dagblad, we expressed concerns about the rising costs of market data charged by exchanges (11 October 2019).

• In this speech during a AFM seminar, Matthijs Pars outlined a number of challenges for supervision.

In the following consultation responses and letters, we responded to an increase in supervision costs:

• Response consultation on amendment to the Financial Supervision Funding Decision 2019 (September 2019
• Letter about supervisory costs for trading firms (January 2020)
• Response consultation change percentages Bbft 2019 (July 2020)

• Response to the ESMA Consultation Paper Guidelines for reporting under Articles 4 and 12 SFTR