The FCA has published its second consultation paper (CP16/19) on implementation of MiFID II. CP16/19 follows on from CP15/43, which the FCA published in December 2015, and covers a wide range of issues, including the framework for position limits, management and reporting for commodity derivative contracts and the way that firms organise themselves to do business and comply with their regulatory obligations. Comments are invited by 28 October 2016.