-The European Banking Federation believes that it is important to adopt the revised ISD as quickly as possible. The underlying objectives of the ISD should be:
Efficient EU markets.
Reducing the cost of capital.
Improving the access of EU investors and increasing confidence.
Furthermore the ISD revision should focus on improving the passport for investment services across the EU, in particular by:
Establishing a clear regime of country of origin.
Eliminating loopholes and barriers to cross-border provision of services.
Establishing a common code of business and marketing conduct.
Including in the ISD a clear definition of a professional investor.
Abolishing the concentration rule in the current ISD 14(3).
Ensuring consistency with other, relevant EU legislation, such as the directives on Market Abuse and Prospectuses and the Banking Directive.
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© Federation Bancaire de l´Union Europeenne
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