We welcome the opportunity to provide feedback to ESMA’s draft proposals for the review of RTS 21 and ITS 4 as well as the proposal for new technical standards for position management controls. Europex’ members have gained extensive experience with the implementation of the MiFID II position limit regime and position management provisions. We are therefore grateful to be given the opportunity to share some of these insights to help further improve the generally positive proposals by ESMA.
Please find our responses to selected questions attached below.
