FOA has responded to the Commission's MiFID Review consultation. It supports the aims of the review, but particularly comments that:

  • changes may place unnecessary and possibly duplicative costs on firms;
  • ESMA may not have the staffing levels to meet the requirements of implementing the changes within the desired timescale;
  • the role of speculators in commodity markets is important – FOA says excessive speculation should be dealt with through position management rather than position limits;
  • commercial purpose forward and spot transactions should stay outside MiFID's scope; and
  • product bans potentially have an enormous impact and the Commission must give more detail on its plans to permit bans. (Source: Press Release)