29 October 2003

FESE Comments on Transparency Directive

In its comments on the Commission Proposals for a Transparency Directive the Federation of European Securities Exchanges (FESE), among others, supports a flexible approach to quarterly reporting taking account of the particular concerns of SMEs regarding the costs of reporting.

FESE therefore proposes either to exempt SMEs in some form, or make quarterly reporting optional and therefore allowing member states the option to introduce or maintain respective provisions. Alternatively, the power to demand additional reporting could be allocated to Exchanges in the framework of their admission rules.

On the Dissemination of information and with respect to the technological developments FESE propagates the mandatory use of IT-based channels and systems for the distribution of company information to the public. However, the details of regulation should differ between the various categories of regulatory information that issuers will have to disseminate and many of the technical and technological details should be left to level II.

On the question of minimum harmonisation FESE is not convinced of the necessity of an explicit opting-in by issuers under the regulation of a host country regulator as proposed by the EMAC Rapporteur. But FESE urges the legislator to include wording in the Directive that Regulated Markets have the unrestricted right to apply stricter disclosure requirements within the framework of their admission rules.

On annual and half-yearly reports FESE questions whether a differentiation should be made between audited and unaudited half-yearly reports. Sharing the view of the EMAC rapporteur FESE is of the opinion that the introduction of a mandatory audit review for half-yearly reports should not be addressed via implementing measures, but (if at all) on level I, after a review period.

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