ESBG position paper on the proposed adjustments to ISD

30 October 2001

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In this position paper the ESBG stated that the commission should not try to achieve harmonisation of all provisions at all cost and within a short period of time as national customer markets are still functioning differently all over Europe and did not really converge or develop in the same direction. Moreover, account must be taken of domestic legal systems, which have developed historically and in accordance with customer markets. In view of that, most investment firms and banks do not (yet) provide their services on a cross-border basis. The ESBG does also not consider that there is a need for a revision of the ISD as wide-ranging as currently proposed.

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