The frequent and systematic basis shall be measured by the number of OTC trades in the financial instrument carried out by the investment firm on own account when executing client orders. The substantial basis shall be measured either by the size of the OTC trading carried out by the investment firm in relation to the total trading of the investment firm in a specific financial instrument or by the size of the OTC trading carried out by the investment firm in relation to the total trading in the Union in a specific financial instrument. The definition of a Systematic Internaliser shall apply only where the pre-set limits for a frequent and systematic basis and for a substantial basis are both crossed or where an investment firm chooses to opt-in under the Systematic Internaliser regime.
Under MiFID II, an SI has obligations for pre-trade and post-trade transparency.
Eurobank as a Systematic Internaliser
Eurobank acts as a Systematic Internaliser for Greek Government Bonds. For the obligations of pre-trade and post-trade transparency Eurobank uses the arrangements of the APA and ARM of the ATHEX GROUP.
Eurobank will assess whether it is an SI in a (sub) class of instruments, on a quarterly basis based on computations made public by ESMA from time to time. In the event that Eurobank does not meet the thresholds for inclusion in the SI regime at that time, it will consider its voluntary SI status in the relevant sub-asset classes.