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FCA Revises List of MiFID II Position Limits

The UK Financial Conduct Authority (FCA) has reviewed the bespoke position limits set for a number of commodity derivatives traded on UK venues.

Following its review and as a result of strong growth in some commodity derivative contracts, the FCA has increased the limits of approximately 20 commodity derivative contracts as of February 8.

There has been one reduction in the position limit for UK Feed Wheat, which will take effect from April 8, giving market participants an adjustment period of two months.

The FCA also has marked a number of commodity derivative contracts as “TBA,” where they believe the current 2,500 limit would not be appropriate and could have the adverse effect of constraining activity and growth in those contracts. The FCA intends to review position limits that now appear to be out of date and calculating new ones as soon as possible. In the meantime, no limit is applicable to contracts marked as “TBA.”

The FCA’s webpage on position limits for commodity derivatives contracts is available here.

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Carolyn H. Jackson, International Attorney, Katten Muchin law firm
Partner

Carolyn Jackson is a partner in Katten Muchin Rosenman UK LLP and is a Registered Foreign Lawyer. She provides US financial regulatory legal advice to a broad range of market participants, including commercial banks, investment banks, investment managers, broker-dealers, electronic trading platforms, clearinghouses, trade associations and over-the-counter derivatives service providers.

Carolyn guides clients in the structuring and offering of complex securities, commodities and derivatives transactions and in complying with US securities and commodities laws...

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Nathaniel Lalone, Katten Muchin Law Firm, Financial Institutions Attorney
Senior Associate

Nathaniel Lalone, a partner at Katten Muchin Rosenman UK LLP, has a broad range of experience in the regulation of financial products and financial markets, and frequently provides regulatory and compliance advice to trading venues, clearing houses and buy-side firms active in the over-the-counter (OTC) derivatives, futures and securities markets. He is actively involved in advising clients on the implementation of MiFID 2 and MiFIR in the European Union as well as the international reach of US financial services regulation. He also has significant experience with structuring and documentation relating to OTC derivatives and structured products.

Prior to joining Katten, Nathaniel was a member of the US Regulatory and the Derivatives and Structured Finance practices at Allen & Overy LLP.

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Neil Robson, private equity fund managers counselor, Katten Law Firm, London
Partner

Neil Robson, a regulatory and compliance partner with Katten Muchin Rosenman LLP, focuses his practice on counseling hedge and private equity fund managers and other investment advisers on operational, regulatory and compliance issues. He regularly addresses Financial Conduct Authority (FCA) and EU authorization and compliance under both the EU Alternative Investment Fund Managers Directive (AIFM Directive) and MiFID, cross-border issues in the financial services sector, market abuse, anti-money laundering and regulatory capital requirements, formations and buyouts of...

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