In its response to CESR’s Consultation on Level 3 guidelines on
MiFID transaction reporting,
FESE supports greater supervisory convergence and consistency, where these are properly justified and based on a thorough cost-benefits analysis.
FESE urges
CESR to amend the definition of a transaction to avoid divergent national regimes.
CESR is asked to find a way of ensuring that the resulting implementation of this definition is consistent across the EU. In particular, separate reports should be avoided when a chain of transactions in fact constitutes only one.
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