On July 23, 2021, ISDA and the Futures Industry Association (FIA) submitted a joint response to the European Securities and Markets Authority’s (ESMA) 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 revised Markets in Financial Instruments Directive’s ‘quick fix’, which will apply from February 28, 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 relating to a 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 a substantial burden on both the venues and market participants.
Documents (1) for ISDA Response to ESMA on Technical Standards for Commodity Derivatives
Latest
Request to Extend Relief on No-Action Letter 22-18
On July 3, ISDA requested to extend the relief under the Commodity Futures Trading Commission's (CFTC) no-action letter No. 22-18. ISDA requests that the relief is extended until further action by the CFTC resolves the overlapping and contradictory reporting obligations...
Industry Report under Project Guardian
ISDA and Ant International led the Project Guardian FX industry group to develop a new report for implementing tokenised bank liabilities and shared ledger in cross-border payments and foreign exchange (FX) settlement. The joint report is produced under the Monetary...
ISDA Letter to FASB on Agenda Consultation
On June 30, ISDA submitted a comment letter to the Financial Accounting Standards Board (FASB) in response to the proposal File Reference No. 2025-ITC100, Agenda Consultation. In the letter, ISDA believes the highest priority should be given to expanding the hedge...
Joint Paper on UK EMIR Reform
On July 1, ISDA and UK Finance published a paper, which recommended a set of reforms for the UK European Market Infrastructure Regulation (UK EMIR), carefully considering each EU EMIR 3.0 reform and asking whether we would wish to adopt...