-The Union of Industrial and Employers' Confederations of Europe (UNICE) argues that the Lamfalussy procedure provides considerable room for improvement as regards the consultation process although the experience is rather limited. Market participants and business ought to be consulted more smoothly and efficiently than is the case at the moment. UNICE welcomes the establishment of a Market Participants Advisory Committee as part of the consultation process. However, it should not only be limited to representatives of financial service providers, investors and shareholder groups but should also include representatives of user groups such as business organisations.
UNICE claims the following improvements to be made in the process:
Article 202 should be amended
Closely involve and consult industry
Transparency of the process should be enhanced
CESR has to be properly resourced before giving it additional responsibilities
Better consistency of definitions among all directives is essential
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