On July 23, ISDA responded to a consultation from the Bank of England (BoE) and Financial Conduct Authority (FCA) on the additional draft Q&A for position-level reporting of spread bets under the UK European Market Infrastructure Regulation (UK EMIR) Refit. ISDA agreed with the proposal to require reporting of spread bets at position level only, while highlighting the requirement for all derivatives to be reported at the trade level, and the mutual agreement needed between parties for position-level reporting to occur.