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In mid-February this year, CEA presented the Commission with a detailed “Preliminary Position Paper” on the Commission draft proposal for a directive dated 5 January 2001. Since there was little change in the wording of the final directive adopted by the Commission on 24 April, most of the comments mentioned in the “Preliminary Position Paper” remain valid.
However, some major points remain to which the CEA attaches utmost importance. CEA wishes to express its serious concern on four main items:
1. Minimum harmonisation
2. Definition of a Financial Conglomerate
3 Deduction of capital holdings in a financial institution
4 Supervision of unregulated entities in financial conglomerates