ESMA_QA_1525

Status: ✅ Answer Published

Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/1525

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Regulatory Context

Regulation : MIF2

Level 1 Regulation: Markets in Financial Instruments Directive II (MiFID II) Directive 2014/65/EU- Secondary Markets

Level 2 Regulation: No information available

Level 3 Regulation: No information available

Topic: Position reporting

Subject Matter: Positions held by an investment firm on behalf of their clients

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Question

Submission Date: 07 July 2017

Do positions held by an investment firm on behalf of their clients add to the investment firm’s own positions?

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ESMA Answer

Answer Date: 07-07-2017

[ESMA 70-872942901-36 Commodity derivatives Q&A, Q&A 4.1] Article 57(1) explicitly introduces the possibility that positions are held on behalf of another entity for legal or operational reasons. In order to avoid double counting, such positions are only to be reported as the positions of the person on whose behalf they are held. They are not to be added to or netted against other positions held by the investment firm.

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This document was automatically extracted from the ESMA EMIR Q&A database.