Europex welcomes the opportunity to respond to the IOSCO consultation on Good Practices concerning Over-the-Counter Commodity Derivatives Markets, which follows IOSCO’s Targeted Implementation Review and seeks to support the implementation of Principles 12, 15 and 16 on the collection of OTC position data and the management of disorderly markets.
We welcome IOSCO’s emphasis on proportionality and risk sensitivity. As exchanges already have a comprehensive set of tools to ensure fair and orderly trading, we support the existing needs-based approach and caution against introducing systematic OTC position reporting through exchanges. We also stress the importance of maintaining a clear distinction between the roles of regulators and exchanges. Rather than adding new reporting obligations, we encourage jurisdictions to make better use of existing data, reduce duplication, and strengthen cooperation among authorities, particularly between energy and financial market regulators.
Find the full paper attached.
