Article 11 of Commission Delegated Regulation (EU) 2017/567 of 18 May 2016 as published in the Official Journal of the European Union on 31 March 2017 (the ‘Transparency obligation’), requires that, ‘Market operators and investment firms operating a trading venue and systematic internalisers shall disclose the price and other terms and conditions for the provision of the market data in a manner which is easily accessible to the public’. This document is intended to cover the relevant disclosures required by the Transparency obligation, and for ease of accessibility to the public is published on the Tradeweb website.

This disclosure is effective from 3 January 2018.

(a)  Price lists  This section details TWE’s current market data price list. 

Data Disclosures Fee Shedule updated

(b) Price changes

Date of the last licence fee adaption for market data: 3 January 2018

(c) Content of the market data 

Information on the pre-trade and post-trade market data ratio is not currently available. Market data has not previously been made available by TWE MTF, and waivers and deferrals have not previously been applicable.

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(d)  Revenue from market data

Information on the revenues accrued from market data and the proportion of that revenue compared to the total revenue of TWE is not yet available, as market data has not previously been made available.

Revenue obtained from making market data available: limited, 0% of total revenue of Tradeweb Europe Ltd. (rounded).  

(e) How the price was set

With MiFID go-live we made real time market data available for the first time. Demand for the data was hard to predict and subject to several significant unknowns. These included: the number of liquid instruments, the percentage of transactions that are deferred, and the quality of the data.

As direct costs of the provision of market data we identified market data sales, market data business management, APA build, APA support, distribution infrastructure, and website built.  Joint costs were identified by our market data and finance team. They include Trading Infrastructure, MiFID platform compliance and MiFID conformance.  The cost allocation methodology used is consistent with our general approach to cost allocation in the company.

The pricing for market data was set as such that it would cover the cost and generate a reasonable margin based on highly uncertain revenue projections. As of today the actual fees generated from market data do not cover the cost.