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ESMA permits NCAs to publish position limits directly

ESMA yesterday issued this document, stating that they had agreed with National Competent Authorities (NCAs) that they may publish position limits under MiFID II directly without having to wait for ESMA to issue an opinion on them. There is also a similar arrangement for pre transparency waivers. The document states that there is no longer … Continue reading

FCA Hedge Exemption application guide and form

The UK’s Financial Conduct Authority (FCA) has recently updated their MiFID Ii Commodity Derivatives page (see here). The page now contains a guide and step by step walk through for Non Financial Entities (NFEs) to apply for a hedge exemption from position limits under RTS 21.  The guide can be found here and the step … Continue reading

MiFID II enforcement

With just over 3 months to go until the start of MiFID II, many companies are struggling to meet the deadlines (see here). Those who will require authorisation or a variation of permissions under MiFID II, have a great deal to prepare before that date. However, non investment firms such as energy and commodity traders … Continue reading

LEIs required soon

The Legal Entity Identifier initiative was born out of the G20 measures put in place to reduce systemic risk, at the same time as the declaration which led to  rules such as EMIR and the Dodd Frank Act being enacted. The rationale for the initiative is to form a global and reliable list of each … Continue reading

FCA issues further reminder for firms to apply for MiFID authorisation

The UK’s Financial Conduct Authority has issued a further update reminding firms that need to apply for authorisation or a Variation of Permissions under MiFID II to apply as soon as possible, if they have not done so already. The updated notice can be found here. The notice follows previous reminders (see here). The notice … Continue reading

Brexit developments

While Brexit has been making general political headlines (for example see The Telegraph here), more sector specific issues are of key importance, if planning for March 2019 is to be at all possible. Last week Christopher Giancarlo, the Chair of the CFTC gave this speech at the Bürgenstock conference. The speech includes comments relating to … Continue reading

Developments in MiFIR’s open access arrangements

Articles 35 and 36 of MiFIR and the associated regulatory Technical Standards (RTS 15) and Delegated Act legislate for open access between trading venues and CCPs so that market participants can choose a CCP when trading on a specific venue, and so that a user of a CCP has a choice of execution venue. Articles … Continue reading

MiFID II countdown – issues and lack of readiness and new information

With just over 3 and a half months until the start of MiFID II, there is a great deal for firms to do, especially those who are Investment Firms. Yesterday the Electronic Debt Markets Association (EDMA) wrote this letter stating that as things currently stand, MiFID II is likely to drive trading off venues, or … Continue reading

EMIR reporting changes nearly here

On 1st November 2017 the fields and formats with which trades must be reported under EMIR will change (see here). This is the third set of changes to be made since reporting originally went live on 12th February 2014, and is therefore referred to by some as “Level 3 validations”, following the naming convention of … Continue reading

MiFID II and GDPR interaction

The Global Data Protection Regulation applies from May 2018 and contains many requirements relating to the personal data. Controllers and processors of data in scope must comply with the rules wherever they are located, with heavy penalties for non compliance. The European Commission has issued this info-graphic which summarises the rules. This page on the … Continue reading