FIA, ISDA, GFMA, EFET, LEBA and WMBA jointly submitted a comment letter to ESMA to ask for clarification on certain aspects of the new position reporting regime for commodity derivatives under MiFID II, which will apply from 3 January 2018. The letter proposes a definition for the terms “client” and “end-client” in Art. 58 II MiFID II, how to address legal issues arising from an obligation to report positions all the way through to the end-client, how duplicative reporting can be avoided and proposes a deadline by when reports need to be submitted.
