Date: December 4, 2015
Issue: Commodity trading activities; margin; and clearing
To: Commissioner Jonathan Hill, Directorate-General for Financial Stability, Financial Services, and Capital Markets Union, European Commission
Filing Type: Regulatory; International
Description: The letter to the European Commission regards recent standards from ESMA on MiFID II regulatory technical standards, which would capture several non-financial companies with ancillary commodity trading activities under its margin and clearing requirements. In short, the letter highlights that ESMA’s approach to commodity hedging and trading activities is overbroad and ignores the important business and liquidity management benefits that such trading provides.