On February 15, ISDA and the Association for Financial Markets in Europe (AFME) submitted a joint response to the UK Financial Conduct Authority’s (FCA) consultation on the reform of the UK commodity derivatives regulatory framework. The consultation sought to remove unnecessary burdens on firms and strengthen the supervision of UK commodity derivatives markets.

In the response, the associations strongly support the FCA’s proposal to apply a narrower position limits regime that is more proportionate to the risks associated with certain commodity derivatives contracts. However, the associations express concern over the proposed approaches for setting position limits and adding additional reporting obligations. They note the complex and burdensome frameworks proposed can discourage participation in UK trading venues by non-UK participants and may have a negative impact on the competitiveness of UK markets. The response also recommends a longer implementation period of at least 24 months due to the scale of the operational and technical changes required.