On 23 July, FIA and ISDA submitted a joint response to ESMA's consultation on technical standards (draft RTS 21 and ITS 4) for commodity derivatives following announced changes to the position limits regime as part of the MiFID II 'quick fix', which will apply from 28 February 2022.
While members are largely supportive of draft RTS 21 and ITS 4 and believe they will improve the position limits regime, there are some areas of concern.
These include ESMA's proposals around the scenario where deliverable supply is substantially higher than open interest, and proposals relating to position management, which the associations believe would benefit greatly from increased flexibility for trading venues to avoid substantial burden on both the venue and market participants.
The associations make recommendations and suggest changes in the joint response.
Download the full response here.
