The London Stock Exchange has responded to CESR’s consultation on draft technical advice on Level 2 of the Transparency Directive (CESR /05-267). The key points of our response are as follows:
- It is important that issuers and investors are afforded a clear level of certainty, in order to achieve this there needs to be a much clearer definition of media than the one given in the draft advice. We also believe that there needs to be an approval regime for service providers – without one, an unnecessarily high regulatory obligation will be placed on issuers, and it is hard to see how minimum standards will be enforced.
- A holistic approach needs to be taken to the questions of dissemination of regulated information, the establishment of a mechanism for the central storage of regulated information and an electronic network for EU wide storage. If CESR and the Commission fail to facilitate electronic solutions for the dissemination of regulated information then the other tasks will become disproportionately more difficult and expensive - potentially to the extent that they become unfeasible.
- We are against the proposal that service providers must be able to release regulated information 24 hours a day, seven days a week: we believe this would increase costs and also put European investors at an unfair disadvantage.
- We do not believe it is the role of CESR to determine pricing decisions - pricing policy is a complex area and we believe these decisions are best left to the market.