Responding to the
CESR consultation on Guidelines on
MiFID Transaction reporting the German
ZKA strongly support the fact that
CESR is obviously striving to identify practical solutions instead of pursuing formal legal interpretations. The
ZKA underlined the importance to establish a common understanding between the supervisory authorities regarding the central issues of a European reporting system. This is meant to be a prerequisite for the market players’ being able to implement the reporting obligation on a clear legal basis.
“We believe this to be one of the main objectives that should be achieved at Level 3 of MiFID.”, ZKA says. “In any case, investment firms need beyond a reliable basis sufficient time for implementation and adaption.”
As for both the programming and the necessary test runs time is crucial, ZKA calls for CESR to adopt the Guidelines very soon and to ensure that all open issues are finally clarified.
Joint committee operated by the central associations of the German banking industry
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© ZKA - Zentraler Kreditausschuss
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