Response to CESR's second request for advice on implementing measures on the Markets in Financial Instruments Directive (MiFID)
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The London Stock Exchange has responded to a consultation by the Committee of European Securities Regulators requesting advice on implementing measures on MiFID. The response highlights serious concerns regarding the challenging implementation deadline given the significant systems development facing market participants and infrastructure providers. We call on CESR to avoid complexity and over-prescription in its advice to the Commission, as this will minimise the impact. In particular, CESR should recognise that exchanges already have detailed rule-books, so CESR should only offer general advice and principles in relation to exchange transparency. The original consultation is available at: http://www.cesr-eu.org/
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