FIA, alongside ISDA, GFMA, CMC and CMCE, has responded to IOSCO’s consultation on best practices for OTC commodities position reporting. The associations support IOSCO’s objectives to enhance market integrity, orderly trading and resilience in OTC commodity derivatives markets, but emphasise that these goals should be achieved through better use of existing data and stronger cross-border regulatory cooperation rather than introducing new reporting requirements.
The associations highlight that significant volumes of OTC derivatives data are already reported to trade repositories and accessible to regulators, and call for improvements in data quality, standardisation and sharing arrangements to enable more effective supervisory outcomes.
The response strongly opposes proposals that could lead to mandatory or systematic OTC position reporting to exchanges or additional reporting layers, warning these would be duplicative, burdensome and potentially harmful to market functioning. Instead, it advocates a targeted, risk-based approach, where exchanges can request specific OTC data on an ad hoc basis when justified, while broader oversight and intervention should remain with public authorities.
The associations also caution against expanding the regulatory perimeter to physically settled commodity forwards and stress the importance of maintaining clear roles, proportionality, and coordinated global regulatory frameworks.
Read the response in full.
