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10. CFDs: An Update

Building on the foundations laid in the November 2023 session, this update shares what we have actually seen across five live CFD Refit implementations, and crowdsources the questions our community wants put to ESMA.

/ Summary

We dig into the partial close versus offsetting trade methodology (Guidelines 443 and 444), trade level versus position level reporting trade offs, the unresolved ambiguity around event date ordering and end of day position interpretation, and the operational consequences of the Guidelines 142 election on position maintenance versus closure. We share five sets of open ESMA questions covering execution timestamp, intraday partial close reporting, blank event_type usage, price and notional aggregation rules, and subsequent position UTI mechanics. Aimed at retail brokers and CFD desks looking for industry aligned answers to the trickiest edge cases.

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