ISDA has responded to the UK Financial Conduct Authority’s (FCA) consultation paper CP 15/43. It is the first FCA consultation on implementation of the revised Markets in Financial Instruments Directive, and at least a further consultation is expected. CP 15/43 seeks views on issues related to the FCA’s regulation of the secondary trading of financial instruments, and some points covered in the consultation may be affected by yet unpublished European Union legislation and guidance.