-The European Savings Banks Group, ESBG, published a position paper on the Commission second consultation document on “transparency obligations for issuers whose securities are admitted to trading on a regulated market”. 
The ESBG  states that one of the main problems of capital market regulations concerning disclosure lies in their need to be coordinated with trade law related accounting requirements. In this respect, the Commission’s reviewed paper presents some weaknesses in the way it deals with small and medium-sized debt security issuers not listed on the stock exchange.
The ESBG  also criticizes the Commission’s proposal to apply half-yearly reporting obligations to issuers of listed debt securities as obligations already exist for these issuers to publish information about their current financial situation and prospects. Against this background, the ESBG  does not see the need to present investors with half-yearly reports on top of the current annual financial statements and the information already provided in the framework of ad-hoc disclosures. 
The Commission proposal to introduce a single term for publishing annual accounts together with the fourth quarterly report is also under critique and is considered to be too tight. Instead, ESBG  prefers the possibility of releasing a forth quarterly report included in the annual report within a period of at least three months from the end of the year.
ESBG  Position Paper
      
      
      
      
        © European Savings Banks Group
    
      
      
      
      
      
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