On January 27, ISDA responded to the European Securities and Markets Authority’s (ESMA) discussion paper on measures for implementation of the rules on market abuse and insider dealing under the Market Abuse Regulation (MAR). The letter highlights that any Level 2 legislation should not go beyond the mandate provided by the regulation and should avoid over prescriptive requirements. Implementing measures should also take into account the specificities of different instruments and market participants, while ensuring a level playing field. In particular, ISDA asked for clarification of rules on market soundings, indicators of market manipulation and public disclosure of inside information and delays.