On 28 October, FIA filed its response to FCA Consultation Paper 16/19 on MiFID II implementation in the UK. Among various recommendations, we:
- proposed amendments to the definition of “commodity derivatives”;
- supported the comments of GFMA’s Commodities Working Group relating to the timing of compliance with commodity position limits and to the position reporting regime;
- requested further clarification with respect to certain transitional provisions; and
- proposed some drafting amendments to CASS 6.3.6A1(c), 7.11.59 and 7.11.60.