The key points of EuropeanIssuers are:

- there is support for non-harmonisation of the legal framework governing whom an issuer has to recognise as the legal holder of its securities;
- however, we are not convinced of the need for a Directive as it stands;
- there is a need for a EU legal framework for shareholder identification;
- there is a need for ensuring integrity of the issue in particular through a legal obligation to maintain the correct number of securities and to reconcile regularly;
- We do not agree that the costs associated with more complex share ownership structures should be subsidised by domestic shareholders particularly where cheaper alternatives are available;
- earmarking and control agreement should be optional methods, which Member States may retain in their own jurisdiction; and
- the conflict of law rule should not include the head office as connecting element to base the applicability of law in case of conflict.

EuropeanIssuers position