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Over recent years, the company has gained extensive experience of Regulatory Reporting - particularly the reporting of commodity positions required by the CFTC's Large Trader Reporting rules and under the EU's MiFID II.
The relevant US legislation is Part 20 of Title 17 of the Code of Federal Regulations: Large Trader Reporting for Physical Commodity Swaps.
Part 20 requires that all clearing organisations, clearing members and swap dealers report details of positions held by both themselves and their counterparties in instruments which reference the price of 46 named US commodity futures contracts. It is important to note that the regulation is not restricted to US clearing organisations or swap dealers, or to positions held by US counterparties - it's scope is restricted only by the list of covered contracts.
Part 20 also requires that reporting entities file a Form 102S for each party with a reportable position, providing name and address details of each party. The CFTC's Ownership and Control Reporting (OCR) rules provide the specific details in this regard.
Further details about the CFTC and Part 20 in particular can be found on the pages below:
The relevant EU legislation is MiFID II (Directive 2014/65/EU of the European Parliament and of the Council of 15th May 2014), specifically Title IV (Position Limits and Position Management Controls in Commodity Derivatives and Reporting). Title IV contains just two articles:
EU directives (as opposed to regulations) direct member states of the EU to enact legislation that meets some objective. EU regulations apply to all members states without those member states having to enact their own legislation. MiFID II (and MiFID before it), it is a directive; this is in contrast with MiFIR, which is a regulation.
So, technically, Articles 57 and 58 do not direct investment firms to do anything. Instead, they direct EU members states to ensure that the relevant competent authority within those member states performs some activity; they also delegate the task of specifying the actual implementation detials to the European Secutities and Markets Authority (EMSA).
Article 57 requires that competent authorities establish and apply position limits for commodity derivatives, and that ESMA determine the methodology for doing so. The limits do not apply to positions held for commercial hedging purposes. Articla 57
Article 58 requries that - on a weekly basis - trading venues which trade commmodity derivatives or emission allowances (or derivatives thereof) report position data to both the relevant competant authority and to ESMA. It further requres that - on a daily basis - investment firms trading in commodity derivatives or emission allowances (or derivatives thereof) report position data to the relevant competent authority for both positions traded on a trading venue and economically equivalent OTC contracts.