SIFMA AMG Submits Comments Regarding ESMA Guidelines for the Application of C6 and C7 of MiFID1

The Asset Management Group of SIFMA ("SIFMA AMG") provided comments on the Consultation Paper by the European Securities and Markets Authority ("ESMA") regarding guidelines on the application of C6 and C7 of Annex I of MiFID1.

SIFMA AMG responded to a number of questions provided in the ESMA Consultation Paper, including the following:

• whether it agreed with ESMA's specification that C6 include commodity derivative contracts that "must" be physically settled and contracts that "can" be physically settled;
• whether there are alternatives for or additions to the proposed examples of "physically settled" that ESMA should consider within the definition of "physically settled" in C6; and
• whether it agreed with ESMA's discussion of the relationship and lack of conflict between the definitions in C5, C6 and C7.

See: SIFMA AMG Comment Letter to ESMA.