SFA Responds to IOSCO’s Consultation Report on Pre-Hedging

On February 21, SFA submitted a comment letter to the International Organization of Securities Commissions (“IOSCO”).  In the letter, SFA addresses questions presented in IOSCO’s consultation report including those around the proposed definition of pre-hedging; the use-cases of pre-hedging and how risk management should be understood in those contexts; the relationship between client and the dealer in the pre-hedging process; as well as the necessary disclosures.