FIA draft Q&As on position reporting submitted to ESMA

Following a joint FIA/EFET/GFMA/ISDA letter to ESMA in December 2016, the trade associations jointly submitted draft Q&As to ESMA on position reporting under Art. 58 of MiFID II. Reflecting our positions in the December letter, the draft Q&As propose a definition of end-client, clarify how positions of clients and clients of those clients should be reported and make suggestions how duplicative reporting could be avoided.