On 22 February, FIA, GFMA, ISDA and EFET jointly submitted two comment letters to ESMA on the position limits regime to be introduced under MiFID II. The first letter relates to the application of position limits to products listed in Annex I, Section C.10 of MiFID II and we argue that position limits should only apply to those products with a link to commodities, i.e. not inflation swaps. The second letter requests a clarification from ESMA that contracts traded on a third-country (i.e. non-EU) venue should not be considered OTC for the purposes of the position limits regime.
