FIA and the International Swaps and Derivatives Association have jointly responded to a European Securities and Markets Authority call for evidence on pre-hedging activities. FIA and ISDA offered comments on ESMA’s proposed definition for pre-hedging, how to distinguish it from hedging, the relationship with MiFID and MAR including legitimate and illegitimate indicators, the treatment of RFQs and more.
ESMA’s previously addressed pre-hedging in the context of MAR Review, identifying fundamentally diverging opinions on this practice including the fact that some market participants see pre-hedging as essential for risk management and the correct functioning of the markets, whereas other stakeholders consider that pre-hedging may amount to insider trading.
