FIA (as FOA) joined forces with ISDA and EFET to comment on the definition of appropriate position limits under Article 59 of MiFID in ESMA's level 2 work. In the comment letter, the associations set out the principles around which they believe futures position limits should be calibrated, including limiting the application of position limits to the delivery (spot) month only; and applying limits to net long and short positions, across global trading venues, and across ETD and economically equivalent OTC contracts.
