On October 27, MFA submitted a joint letter with AIMA to the European Commission on the Short Selling Regulation in relation to the Commission’s Capital Markets Union (CMU) initiative. The letter sets out the following recommendations that would enhance the ability of firms to efficiently comply with, and report information pursuant to, the Short Selling Regulation:
- The establishment of a centralized notification and publication mechanism for significant net short positions in shares and sovereign debt
- The establishment of a centralized EU source of issued share capital data and a centralized list of in-scope instruments
- Delay of significant net short position notifications from T+1 to T+2
- The removal of incremental thresholds for additional private notifications for shares
- Enhanced harmonization of national competent authorities’ interpretations of the Short Selling Regulation
- Clarification that both duration and delta adjustment of derivative positions are permitted for net short position calculations in sovereign debt
- Harmonization of publication and terms of temporary short-selling bans
