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MiFID II update: Position limits changes and wider news – MiFID III

There has been some activity on the MiFID II side of things since our last post (see here), a small proportion of which relates to energy and commodities:

Recently the UK’s Financial Conduct Authority(FCA) updated their master limits spreadsheet. The new version can be found here. Some significant changes have been made to the aggregations found within it, and the sheet is now shorter than it was previously. In addition there has been a small change to the UK Natural Gas contract and some new contracts added (about 13). A “differences” version of the spreadsheet can be requested from ETR Advisory by emailing

In the wider financial world, the impact of MiFID II is being felt with more magnitude. While Andrew Bailey, Chief Executive of the FCA, has commented on the impact of MiFID II on the resulting quality of sandwiches (see here), some of the impacts are more significant.

This article on the FT Adviser discuses the fact that many smaller financial advisory firms are not fully MiFID II compliant, and reports on a warning from the FCA that more firms can expect enforcement. Rules around “research unbundling” have also had an impact: This article on reports that US brokers are benefiting from the more onerous rules now in force in the EU, as firms have an incentive to chose from a smaller number of brokers. On the equity side, this article on the Financial News web site reports on the unintended consequences of transparency regulation.

As a result, some regulators are turning their thoughts on changing MiFID II, in order to “tweak” it. This speech given by Robert Ophèle, chairman of the AMF (the French National Competent Authority) talks of changing MiFID II where it has “gone too far”. This article on the Financial News web site reports that Kay Swinburne MEP has stated that MiFID III could be “around the corner”, although this legislation may well be changes to MiFID II based on data collected. This speech, also by Kay Swinbunne, reported on The Trade News web site, reassures that MiFID III is likely to be less onerous than MiFID II.



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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