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More MiFID II pushback -from the “agri” sector

See here for a letter from a consortium of industry associations in the agricultural sector pushing back against several aspects of the MiFID II Ancillary Activity test (RTS 20) and Position Limits (RTS 21).

With respect to RTS 20, the letter argues for the re introduction of a “capital test” as  others have. In addition, the letter request that the capital test use the standard CRR model as numerator, and total assets minus current debt as numerator. ESMA suggested several options to the European Commission in their opinion document issued in May. It now remains to be seen what form of capital test, if any, the Commission introduces in the next version of the test.

With respect to RTS 21, there is push back against the lower limits possible for certain agricultural commodities. Position Limits are seen by many to be a tool to prevent unwanted speculation in the food market, which has resulted in support for stricter limits from many quarters.


About avivhandler

Aviv is the Managing Director of ETR Advisory, a niche consultancy focused on the regulation of the commodity, energy and financial markets. He has more than 23 years of experience in the financial, energy and commodity markets, covering regulatory compliance, credit, risk and financial technology. Prior to founding ETR, he was Partner at SunGard Global Services, where he built a Centre of Excellence in European Energy and Commodity Regulation. Before that, he founded Coherence, a consulting firm specializing in credit risk in commodity and energy trading as well as software product management. The credit practice ultimately became part of Sirius Solutions, where he was the Managing Director of Europe. He has also held management roles at KWI and Iris Financial, among other organizations. Mr. Handler holds a degree in computer science from Imperial College, University of London.


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