The German Savings Banks and Giro Association (DSGV) states that the content of the Common Position of the Council and the text adopted by the EP at first reading corresponds to a large extent and the existing differences should be consolidated within a consistent compromise text.
As to the topic of internalisation, the DSGV is convinced that there is a fundamental agreement
between the EP Resolution at first reading and the Common Position of the Council.
both agree that internalisation is a phenomenon which requires special regulation at a Directive level in order to ensure fair competition between banks and regulated markets and to safeguard a high level of market efficiency and price quality for all market participants
both favour the introduction of a definition of “systematic internalisation” and a restriction of the scope of the pre-trade transparency regime to the operators of internalisation systems
both agree that limit orders of private and professional clients which cannot be executed immediately on an internalisation system are to be made accessible to other market participants, preferably by forwarding them to a regulated market or multilateral trading facility (MTF)
both institutions consider the question of open access to internalisation systems to be an important regulatory matter.
With regard to the conduct of business rules and organisational requirements for investment firms, the EP text appears to be preferable in principle because it renders a greater degree of flexibility when implementing the standards without disregarding the legitimate interests of investor protection. However, the content of both texts corresponds to a large extent, so it should be possible to align the two texts in a suitable manner.
The EP text as a whole is clearer and technically more fully developed, whereas the Council text contains a series of unclear points which may have a detrimental impact on the efficient and reliable supervision of internalisation systems. On the other hand, in some respects the Council text pursues the concept of comprehensive pre-trade transparency for internalisation systems more consistently than the EP text does. Insofar, we have a preference for the Council text.
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