FIA files letters to ESMA on position limit proposals under MiFID II

At the end of September 2016, FIA filed jointly with ISDA, GFMA, EFET and WMBA two letters to ESMA, asking for clarifications regarding the scope of the position limits regime under Art. 57 of MiFID II. We argue that position limits should not apply to non-commodity contracts referred to in Annex I Section C.10 of MiFID II (for example, inflation swaps) or to securitised commodity derivatives.  

Please see the two letters in Resources on the right.