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The FBE notes that the transposition of the MiFID’s main provisions has been brought a good degree of consistency across Member States.
However, the FBE is unsure about the Commission’s approach, which brings together in one questionnaire questions of transposition of the MiFID rules by Member States as well as questions of implementation of the rules by firms.
FBE reminds that implementation within the industry follows Member States’ transposition of the rules and more time is needed for new practices to fully bed down. Also, implementation of the MiFID rules is in the first instance a question of compliance, which should be assessed by the national authorities.
Therefore, the FBE suggests that the Commission should primarily focus on such questions of transposition in the narrower sense and leave aside questions of implementation within firms.